BAKER STREET ADVISORS, LLC

Part 2A of Form ADV The Brochure 575 Market Street, Suite 600 San Francisco, CA 94105 BakerStreetAdvisors.com Updated: March 2024 This brochure provides information about the qualifications and business practices of Baker Street Advisors, LLC (the "Advisor," “We” or “Baker Street”). If you have any questions about the contents of this brochure, please contact us at 415.344.6180. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about the Advisor is also available on the SEC’s website at: www.adviserinfo.sec.gov.  Table of Contents Material Changes ............................................................................................................................................... 3 Advisory Business .............................................................................................................................................. 4 Fees and Compensation .................................................................................................................................... 5 Performance-Based Fees and Side-by-Side Management ............................................................................... 7 Types of Clients ................................................................................................................................................ 7 Methods of Analysis, Investment Strategies and Risk of Loss .......................................................................... 7 Disciplinary Information ...................................................................................................................................... 9 Other Financial Industry Activities and Affiliations ............................................................................................. 9 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................... 10 Brokerage Practices ......................................................................................................................................... 11 Review of Accounts .......................................................................................................................................... 13 Client Referrals and Other Compensation ....................................................................................................... 13 Custody ............................................................................................................................................................ 13 Investment Discretion ....................................................................................................................................... 14 Voting Client Securities .................................................................................................................................... 14 Financial Information ........................................................................................................................................ 14 2 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  Material Changes No material changes have been made to Part 2A of the Form ADV. Modifications reflected in this Part 2A of Form ADV were made for Client clarity. The Advisor’s business activities have not changed materially since the time of the update. 3 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  Advisory Business Baker Street provides investment supervisory services primarily on a discretionary basis to a variety of clients. See the “Types of Clients” section for more information with respect to our clients. Services are provided in accordance with Baker Street’s investment advisory agreement and account supervision is guided by the stated investment objectives of the Client (i.e., maximum capital appreciation, growth, etc.). As of December 31, 2023, Baker Street had assets under management of approximately $14.5 billion on behalf of approximately 504 Clients. Principal Ownership Baker Street was founded in 2003. In April 2015, Affiliated Managers Group, Inc. (“AMG”) acquired an equity interest in the Advisor. The remaining equity interests are held by Baker Street’s Partners. AMG, a publicly traded asset management company (NYSE: AMG), also holds equity interests in certain other investment management firms (“AMG Affiliates”). Further information on AMG and the AMG Affiliates is provided in the “Other Financial Industry Activities and Affiliations” section of this Brochure. In connection with the transaction, Baker Street Advisors converted from a California Limited Liability Company (LLC) to a Delaware LLC. Advisory Services As a general matter, Baker Street does not recommend investing in specific securities. We prepare strategic plans for our Clients by determining our Client’s long-term and short-term financial needs and objectives, risk tolerance or risk-aversion, and tax status. Strategic plans are based on information provided to us by our Clients, financial records, responses to our questionnaires and personal interviews. We design each Client’s investment portfolio based on a thorough evaluation of the individual goals and objectives of the Client. We formulate an investment policy statement and/or asset allocation plan for each Client after analyzing the Client’s financial situation and understanding the Client’s individual investment objectives. The investment objectives, investment restrictions, regulatory restrictions, risk tolerances or other circumstances for each Client are generally documented by the Advisor in an investment policy statement. Following Client approval, Baker Street will implement each aspect of the strategy set forth in the investment policy statement, as appropriate. In connection with the implementation of a Client’s investment policy statement, Baker Street will typically identify unaffiliated independent, third-party investment advisors, mutual funds, or private investment pools, including hedge funds, funds of funds, private equity funds, and other similar investments (collectively “third-party investment managers and funds”) that are believed to be compatible with the Client’s investment objectives, risk tolerances and other Client criteria. As part of the process, we evaluate, select, and oversee these investment managers and funds which we utilize to manage a portion of the Client’s account. We will monitor the investment managers’ and funds’ performance, as well as the various investment markets, to determine if the allocation among these investment options is appropriate or if changes to those options are necessary due to various factors, including changes in macro-economic indicators, interest rates, fiscal policy, geo-political or other factors. Except as noted below in “Other Financial Industry Activities and Affiliations”, the Advisor typically utilizes investment managers and funds which are independent of and unaffiliated with the Advisor when managing Client portfolios. In directing a portion of a Client’s account to be managed by an investment manager (with the approval of the Client), the investment manager will have full investment discretion and trading authority and shall have sole responsibility for the implementation of the investment program with respect to the assets delegated to the investment manager to be managed. In such cases, we will not place orders for transactions in the delegated 4 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  portion of the Client’s account or otherwise exercise trading authority over the delegated assets at any time when such assets are being managed by the investment manager. If a Client should need cash from the portion of the Client’s account managed by an investment manager, the Advisor will inform the investment manager of the amount needed by the Client, but at no time will we place orders for transactions in the Client’s account where the investment manager has trading authority. Investment managers and funds considered for our Clients will be subjected to a due diligence process. Factors considered will include, but not be limited to: reputation, performance record, philosophy, continuity of management, service to Clients, awareness of after tax performance objectives (as appropriate), minimum dollar investment requirement and fees. Information with respect to investment managers and funds (e.g., performance figures, investment style, etc.) will be obtained from tracking organizations, business publications, investment managers, personal interviews, and other sources which we believe are reliable. We may also consider other criteria, including, but not limited to, the administration, recordkeeping and reporting services provided by a manager or a fund. We may retain outside consultants to assist in preparing investment manager and fund search lists. In the event that we retain an outside consultant, we will make the final determination regarding which investment managers and funds that we will make available to our Clients. In certain cases when managing Client assets, the Advisor may select AMG Affiliates or funds managed by AMG Affiliates. Neither AMG nor any AMG Affiliate has any involvement or influence in the Advisor’s selection of investment managers or funds. As such, AMG’s ownership interest in the Advisor does not, in the Advisor’s view, present any potential conflict of interest for the Advisor with respect to our Clients. The Advisor also provides financial planning services, which may include estate and trust services, risk management and insurance services, philanthropy services, income tax consulting, and bill paying services. These services are provided by the Advisor under a separate agreement between the Client and Baker Street. Estate and trust services may require that the Client obtain his or her own independent legal counsel. Baker Street does not provide legal advice or draft legal documents. Fees and Compensation For investment supervisory services, compensation is derived as fee income based upon a percentage of a Client’s assets under management. In each instance, the compensation method is explained and agreed with Clients in advance of any services being rendered. The compensation for our services, which include developing and implementing an investment policy and objectives, monitoring a Client’s investment results, selecting and monitoring investment managers, and reporting to the Client on a quarterly basis, is as follows: Assets Under Management Annual Fee $0 - $4,000,000 0.75%* $4,000,001 - $15,000,000 0.50% $15,000,001 - $25,000,000 0.40% $25,000,001 - $50,000,000 0.30% $50,000,001 - $75,000,000 0.20% 5 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  $75,000,001 - $100,000,000 0.10% $100,000,001 - $200,000,000 0.07% $200,000,001 - $500,000,000 0.05% $500,000,001 - $1,000,000,000 0.03% Above $1,000,000,000 0.01% * For amounts less than $4 million, the fee will be 0.75% not to exceed $20,000 annually. This tier does not apply to Clients with more than $4,000,000 under management. Clients that have assets under management of over $4 million dollars will be subject to an annual fee of .50% on the first $15 million of assets under management. Baker Street management fees are for advisory services only and are separate and distinct from third-party investment manager fees which include additional management fees and may include performance-based fees. Clients will also incur any applicable custodial fees, transaction fees and commissions for securities transactions recommended by Baker Street or the investment managers. Clients investing in mutual funds (including money market funds) and exchange-traded funds will typically pay management and/or other fees to each such fund. Those fees are described in each fund’s prospectus. Clients investing in private funds, including hedge funds, private equity funds and funds of funds will incur expenses associated with the pooled investment vehicle, which may include audit, legal, custodial, and other types of fees. Clients investing in private funds should refer to the private placement memorandum or limited partnership agreement for a detailed description of additional expenses incurred. Fees for Clients, who do not have accounts at SEI, are billed quarterly in advance of one fourth of the annual rate based on a percentage of the Client's assets under management at the end of the calendar quarter. Investment advisory services begin with the effective date of the Investment Advisory Agreement, which is the date the Client signs the Investment Advisory Agreement. For that calendar quarter, fees will be adjusted pro- rata, based upon the number of calendar days in the calendar quarter that the Investment Advisory Agreement was effective. Fees for Clients, who have accounts at SEI, are billed quarterly in arears of one fourth of the annual rate based on a percentage of the Client's assets under management at the end of the calendar quarter. Investment advisory services begin with the effective date of the Investment Advisory Agreement, which is the date the Client signs the Investment Advisory Agreement. For that calendar quarter, fees will be adjusted pro-rata, based upon the number of calendar days in the calendar quarter that the Investment Advisory Agreement was effective. Clients that have assets under management of less than $4 million will be subject to an annual fee of .75%, not to exceed $20,000 annually, calculated as described in the previous paragraph. Clients that have assets under management of over $4 million dollars will be subject to an annual fee of .50% on the first $15 million of assets under management. The portfolio value upon which the percentage fee is based will include the current fair market value of all of the Clients’ investments managed by Baker Street. These investments may include mutual funds, exchange traded funds, limited partnerships, fixed and variable annuity accounts, stocks, bonds, and other securities, selected by the investment managers. While the majority of holdings in Client portfolios are readily priced by 6 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  the Clients’ custodians, certain investments, such as private funds, may require Baker Street to obtain valuations from the fund investment managers, utilize the investment cost, or utilize fair valuation based on estimates received from the investment managers. As such, valuation utilized for the purpose of reporting and fee calculation may differ from that reflected on a Client’s custodial statement. Clients should be aware of their responsibility to verify the accuracy of the fee calculation submitted to their custodians by the Advisor, as the custodian will not determine whether the fee has been properly calculated. As previously described, Baker Street also provides financial planning services, which may include estate and trust services, risk management and insurance services, philanthropy services, income tax consulting, and bill paying services. These services are provided by Baker Street under a separate agreement between the Client and Baker Street. Fees for these services are based on a retainer, hourly rate, or annual fee based on assets under management, as agreed upon between Baker Street and the Client. The Advisor's service may be terminated by either party upon written notification in accordance with the applicable contractual notice of termination. Upon termination, the fees charged for advisory services will be pro-rated. The Client can cancel the Agreement without penalty within the first five days after the signing of the Agreement. Should the Client be invested in a private fund, separate account manager or other vehicle, Baker Street will provide contact information for that investment manager so that the Client can determine with the investment manager if the Client’s funds will be/could be redeemed or if the Client will continue to work with that investment manager or remain invested in the particular investment vehicle. Fees may be negotiated for Clients where specialized investment services are needed or for family members of employees of the Advisor. The Advisor reserves the right to adjust the fee schedule for accounts depending on the size and type of account and the services required. In some cases, negotiation of fees may result in different fees being charged for similar services and may be less than the stated fees. Performance-Based Fees and Side-by-Side Management The Advisor does not charge any performance fees; however, some investment managers or funds recommended by Baker Street may charge performance fees. Types of Clients The Advisor primarily provides investment supervisory services to high-net-worth individuals and associated trusts, estates, pension and profit sharing plans, and other legal entities. The Advisor requires a minimum account size of $5,000,000; however, the Advisor has discretion to waive the account minimum. Methods of Analysis, Investment Strategies and Risk of Loss Baker Street allocates (and/or recommends that the Client allocate) the Client’s investment assets among investment managers and funds in accordance with the Client’s designated investment objectives. In such situations, the investment managers (or, in the case of funds, the fund investment managers managers) shall have day-to-day responsibility for the active discretionary management of the allocated assets. The Advisor will provide the names of the investment managers selected from the investment manager search lists after considering the compatibility of the investment managers’ investment philosophy, minimum investment requirements and other factors with the Client’s investment objectives, risk tolerances and other Client criteria. As a general matter, the Advisor expects that the factors that will be used to determine the names of investment 7 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  managers and funds to be included on the investment manager and fund search lists will include, but will not necessarily be limited to: reputation, management strength, performance record, philosophy, the continuity of management, service to Clients, minimum dollar investment requirement, and fees. This determination is facilitated through a proprietary quantitative analysis, in-person meetings, and statistical screening prior to the engagement of any investment manager or the selection of any fund. In addition, periodic performance and logistical updates are conducted in order to confirm that the investment manager or fund continues to fulfill a Client’s mandate and goals. Although the investment managers and/or fund investment managers shall have day-to-day responsibility for the active discretionary management of our Clients’ allocated assets, Baker Street shall continue to render investment advisory services to each Client relative to the ongoing monitoring and review of account performance, asset allocation and Client investment objectives. Investment Manager Risk: All investing involves risk of loss and the investment strategy offered by Baker Street could lose money over short or even long periods. Additionally, Baker Street relies on the investment expertise and day-to-day management of investments to selected investment managers, subjecting Clients to manager risk. The investment performance of each Client’s portfolio is affected by the investment performance of the underlying securities in which the portfolio invests, as selected by the investment managers. The ability of the portfolio to achieve its investment objective depends on the ability of the underlying securities to meet the Client’s investment objectives and the allocation of the portfolio’s assets among the underlying securities. There can be no assurance that the investment objective of each Client account or any underlying securities will be achieved. Through its investments in underlying securities, as selected by investment managers, each Client’s account is subject to the risks of the underlying securities’ investments and can experience losses. Certain risks of the underlying securities’ investments are described below. Market Risk: Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities, and the funds that own them, to rise or fall. Because the value of Client’s investments will fluctuate, there is the risk that the Client will lose money. Investing in securities is inherently risky: An investment in individual securities or in a portfolio of securities could lose money. The individual investments selected by Baker Street and the investment managers should be deemed speculative investments and are not intended as a complete investment program. The Advisor cannot give any guarantee that any Client will achieve the Client’s investment objectives or that any Client will receive a return of the Client’s investment. Generation of multiple levels of fees and expenses: By investing with investment managers and funds, Clients bear Baker Street fees as well as investment manager and fund fees and, in some instances, expenses. Thus, Baker Street Clients may be subject to higher fees than if the Client invested with an investment manager or in a fund directly. In addition, certain of the private funds may be subject to a performance-based fee or allocation, irrespective of the performance of other portfolio funds. Generally, fees payable to private funds’ investment managers will range from 0.625% to 3.25% (per annum). In addition, certain investment managers to private funds charge an incentive allocation or fee generally ranging from 5% to 25% of a private fund’s net profits or realized return. The performance-based compensation received by an investment manager to a private fund may also create an incentive for that investment manager to make investments that are riskier or more speculative than those it might have made in the absence of the performance-based allocation. Such compensation may be based on calculations of realized and unrealized gains made by the Advisor without independent oversight. 8 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  Each portfolio fund invests independently: Each investment manager and fund will generally invest completely independently of one another and may at times hold economically offsetting positions. To the extent that investment managers and funds hold such positions, Client accounts may not achieve any gain or loss despite incurring fees and expenses in connection with such positions. In performing its services, Baker Street 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 on such information. Moreover, each Client is advised that the Client retains his/her/its responsibility to promptly notify Baker Street if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Baker Street’s previous recommendations and/or services. Cybersecurity Risk: With the increased use of technologies to conduct business, Baker Street is susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyber incidents impacting Baker Street have the ability to cause disruptions and impact business operations, potentially resulting in the inability to transact business, financial losses, violations of applicable privacy and other laws, regulatory fines, penalties or reputational damage. While Baker Street has established a business continuity plan and risk management systems intended to identify and mitigate the risks associated with cyber-attacks, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. Furthermore, Baker Street cannot control the cybersecurity plans and systems put in place by third-party service providers, including recommended investment managers and issuers in which client portfolios invest. Clients could be negatively impacted as a result. Disciplinary Information The Advisor and its employees have not been involved in any legal or disciplinary events in the past 20 years that would be material to a Client’s evaluation of the company or its personnel. Other Financial Industry Activities and Affiliations As noted in “Principal Ownership” above, AMG holds an equity interest in the Advisor. AMG’s equity interest in the Advisor is structured so that the Advisor maintains operational autonomy in managing its business. AMG does not have any role in the day-to-day management of the Advisor. AMG also holds equity interests in certain other investment managers, the AMG Affiliates. In certain cases, the Advisor may select investment managers that are AMG Affiliates to manage Client assets, or may invest Client assets in funds managed by AMG Affiliates. Each of the AMG Affiliates, including the Advisor, operates autonomously and independently of AMG and of each other. The Advisor’s selection of investment managers does not include any involvement or influence from AMG or any AMG Affiliate. As such, AMG’s ownership interest in the Advisor does not, in the Advisor’s view, present any potential conflict of interest for the Advisor’s selection of investment managers or otherwise with respect to our clients. More information regarding AMG, including its public filings and a list of all AMG Affiliates is available at www.amg.com or upon the Advisor’s Clients upon request. 9 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading The Advisor, its Partners and employees may, on a limited basis, buy or sell, for their personal accounts the same securities that may be recommended to Clients. To avoid any potential conflicts of interest involving personal trades, the Advisor has adopted a formal code of ethics (the “Code”) which includes personal securities transactions and insider trading policies and procedures. The Advisor’s Code requires, among other things, that employees:  Act with integrity, competence, diligence, respect, and in an ethical manner with the public, Clients, prospective Clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets;  Place the integrity of the investment profession, the interests of Clients, and the interests of the Advisor above one’s own personal interests;  Adhere to the fundamental standard that you should not take inappropriate advantage of your position;  Avoid any actual or potential conflict of interest;  Conduct all personal securities transactions in a manner consistent with this policy;  Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities;  Practice and encourage others to act in a professional and ethical manner that will reflect positively on yourself and the profession;  Promote the integrity of, and uphold the rules governing, capital markets;  Maintain and improve your professional competence and strive to maintain and improve the competence of other investment professionals; and  Comply with applicable provisions of the federal securities laws. Baker Street’s Securities Compliance Policy requires employees to: 1) pre-clear certain personal securities transactions, 2) report personal securities transactions on at least a quarterly basis, and 3) provide the Advisor with a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such employees have a direct or indirect beneficial interest. All employees of the Advisor are also subject to the AMG Insider Trading Policy and Procedures (the “AMG Insider Trading Policy”). The AMG Insider Trading Policy broadly prohibits the use of material, non-public information, and also imposes restrictions on the trading of AMG’s stock. In addition, the Advisor’s Code of Ethics also includes policies and procedures prohibiting the use of material non-public information that are designed to prevent insider trading by an officer or employee of the Advisor. In the normal course of business, Baker Street is an allocator of Client funds to investment managers and funds. In certain circumstances, however, Baker Street and/or representatives of Baker Street may buy or sell securities that are also recommended to Clients. This practice may create a situation where Baker Street and/or representatives of Baker Street are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. 10 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  Baker Street has established procedures intended to limit conflicts of interest in cases where Baker Street is a related person, or any of its employees buys or sells securities recommended by Baker Street to its Clients. These procedures include the obligation to pre-clear transactions in private placements (which include interests in private investment funds) through Baker Street’s Chief Compliance Officer and a quarterly review of investment activity within the personal accounts of Baker Street Partners and employees. Baker Street utilizes an Advisory Committee which consults on Baker Street’s model portfolios and asset allocation. In certain instances, Baker Street recommends Clients invest with investment managers whose employees serve as members of the Advisory Committee. Baker Street’s relationship with investment managers that serve as Advisory Committee members creates a potential conflict of interest. As Baker Street receives consulting services from the Advisory Committee members, it benefits from the relationship with the investment managers. A copy of the Advisor’s Code shall be provided to any Client or prospective Client upon request. Brokerage Practices When a Client agrees to discretionary management, Baker Street will be responsible for asset allocation and selecting investment managers and funds. The only limitations on our investment authority will be those limitations imposed in writing by the Client. We may recommend that the Client retain an investment manager directly. In those cases, the Client will engage the investment manager directly, and the Advisor will not be a party to that agreement. The Client will retain discretion to engage or disengage the investment manager. The Advisor will charge the Client an advisory fee for the assets managed by the investment manager. Clients should review the disclosure document(s) of the investment managers we recommend to manage their assets for more information on their policies with regard to investment or brokerage discretion. In the course of providing our services, the investment managers we recommend to manage a portion of the Client’s assets will execute trades through broker-dealers. We expect our investment managers to trade through broker- dealers who offer the best overall execution under the particular circumstances. The Advisor will not place orders for transactions in the Client’s account or otherwise exercise trading authority over the Account at any time when a third party investment manager has trading authority over the Account. Absent an existing brokerage relationship, the Advisor will assist the Client with developing a relationship with brokers that the Advisor has a relationship with, which include: Fidelity Institutional (“Fidelity”) and Charles Schwab & Co. (“Schwab”). Baker Street may recommend that a Client establish brokerage accounts with Schwab or Fidelity to maintain custody of the Client’s assets and to effect trades for the account(s). The Advisor will make recommendations based on the needs of the Client and the services provided by the broker/custodian such as the ability to execute trades, margin rates, on-line access to accounts, transaction charges, consolidated reporting, duplicate monthly statements, access to mutual funds, including lower sales charges than for direct purchases and lower minimum purchase amounts. Baker Street has no affiliation with Schwab or Fidelity and receives no monetary remuneration from Schwab or Fidelity, either directly or indirectly. However, Schwab and Fidelity may provide services of value to our Clients and Baker Street; these are described in more detail below. 11 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  As part of the programs offered by Fidelity and Schwab, the Advisor receives benefits that it would not receive if it did not provide investment advice to Clients. While there is no direct affiliation or fee sharing arrangement between Fidelity, Schwab and the Advisor, economic benefits are received by the Advisor which would not be received if the Advisor did not have an established relationship with Fidelity and Schwab. These benefits do not depend on the amount of transactions directed by the Advisor to Fidelity or Schwab. These benefits may include: a dedicated trading desk that services the Advisor’s Clients, a dedicated service group and an account services manager dedicated to the Advisor’s accounts, access to a real time order matching system, ability to block Client trades, electronic download of trades, portfolio management software, access to an electronic interface, duplicate and batched Client statements, confirmations and year-end summaries, the ability to have advisory fees directly debited from Client accounts (in accordance with federal and state requirements), a quarterly newsletter, access to mutual funds, ability to have loads waived for the Advisor’s Clients who invest in certain loaded funds when certain conditions are met and maintained, and the ability to have custody fees waived. Schwab or Fidelity may provide Baker Street with information and services intended to help Baker Street manage and further develop our business enterprise. Schwab or Fidelity may provide these services themselves or may arrange for third parties to provide the services. These services may include educational conferences and events; consulting on various topics such as information technology, compliance, strategic, legal, and business needs; presentations, consulting, publications and conferences on various topics such as regulatory compliance, practice management, human capital, and business succession; support, including financial assistance with mailing packages; and access to employee benefits providers, human capital consultants, and insurance providers. The term “soft dollars” refers to a means of paying brokerage firms for products and services through commission revenue, based on the volume of brokerage commission revenues generated from securities transactions executed through brokers by an investment manager on behalf of advisory Clients. Section 28(e) of the Securities Exchange Act of 1934, as amended, allows Baker Street to pay broker-dealers more than the lowest commission available in order to obtain research and brokerage services without breaching its fiduciary duties to Clients or imposing a duty upon Baker Street to obtain the lowest commission if certain conditions are met and Baker Street makes a good faith determination that the commissions paid are reasonable in relation to the value of the brokerage or research services on behalf of its advisory Clients. In determining if something is research, thus falling within the safe harbor provisions, the controlling principle is whether it provides lawful and appropriate assistance to the investment manager in the performance of its investment decision-making responsibilities. Baker Street currently does not maintain formal soft dollar agreements with Schwab nor Fidelity. However, Schwab and Fidelity provide Baker Street with proprietary research. Baker Street has determined that it would obtain this service regardless of the amount of commissions it generates at Schwab and Fidelity throughout the year. Therefore, Baker Street may not be “paying-up” for proprietary research. Research services received from Schwab and Fidelity are supplemental to Baker Street’s own research efforts, and, when utilized, are subject to internal analysis before being incorporated by Baker Street into its investment process. As a practical matter, it would not be possible for Baker Street to generate all of the information presently provided by broker-dealers. Baker Street may pay cash for certain research services received from external sources and also allocate brokerage for research services, which are available for cash. While the receipt of research services from brokerage firms has not reduced Baker Street’s normal research activities, the expenses of Baker Street could be materially increased if it attempted to generate such additional information through its own staff. To the extent that broker-dealers provide research services of value, Baker Street is relieved of expenses, which it may otherwise bear. In addition, Baker Street has an incentive to select 12 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  a broker-dealer based on its interest in receiving research or other products or services, rather than Client’s interests in receiving lower transaction costs. The availability to Baker Street of the foregoing products and services is not contingent upon Baker Street committing to Schwab or Fidelity any specific future amount of business (assets in custody or trading) or upon Baker Street giving any particular investment advice. However, the terms of any alternative pricing that may apply to Baker Street or our Clients may be based upon the nature and scope of business that Baker Street transacts with Schwab or Fidelity. Trade Error From time to time, Baker Street may make an error in submitting a trade order on a Client’s behalf. When this occurs, Baker Street may place a correcting trade with the broker-dealer which has custody of the Client’s account. For the purpose of reconciling trade errors, Baker Street will keep a trade error account with each custodian. If the trade error results in a debit balance, this amount will be resolved immediately. At Schwab, if the trade error results in a credit balance, the amount can either be withdrawn or remain in the account; money market rates may be paid on credit balances. At Fidelity, effective March 1, 2016, if the trade error results in a credit balance, the amount will remain in the account for one month and can be netted against any debit balances. At the end of each month, any credit balance will be donated to charity. Review of Accounts All Client accounts are reviewed at least quarterly to ensure that an appropriate allocation is in place based on Baker Street’s assessments of market conditions and the circumstances of the Client. Baker Street will provide more frequent reviews as appropriate and as agreed with the Client. General conditions in the stock and bond markets are continuously monitored. Factors triggering reviews, and perhaps triggering buy or sell recommendations of funds or changes in investment managers, include changed circumstances of the Clients, changed general conditions in the stock and bond markets, and changes in management of investment managers. All accounts are reviewed by one of the Partners. There is no set minimum or maximum in place with regard to the number of accounts that each Partner will review. Clients are kept informed about their portfolio activity by receiving copies of transaction confirmations and monthly or quarterly statements from brokerage firms, mutual fund companies, or the custodian. Clients also receive quarterly reports prepared by the Advisor with their quarterly billing statements. The quarterly reports provided by the Advisor may vary from statements provided by brokerage firms, mutual fund companies or custodial statements based on accounting procedures, reporting dates, and/or valuation methodologies of certain securities. Client Referrals and Other Compensation The Advisor does not directly or indirectly compensate any person, other than employees, for Client referrals. Custody Baker Street does not directly or indirectly hold Clients’ funds or securities and does not have the authority to obtain possession of Clients’ funds or securities. All Clients’ accounts are held in custody by unaffiliated broker/dealers or banks, but the Advisor can access many Clients’ accounts through its ability to debit advisory fees. For this reason the Advisor is considered to 13 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105  have custody of Client assets. Account custodians send statements directly to the account owners on at least a quarterly basis. Clients should carefully review these statements, and should compare these statements to any account information provided by the Advisor. In certain instances, Baker Street is deemed, under federal securities laws, to have custody of certain client accounts by virtue of Baker Street’s specific Partners’ roles as trustees to certain accounts, Baker Street’s authority from clients to pay bills from certain accounts, and password access to certain client accounts. In such cases, the assets are maintained by independent, unaffiliated qualified custodians and are subject to an annual surprise custody examination in compliance with Rule 206(4)2 under the Investment Advisers Act. Baker Street is also deemed, under federal securities laws, to have custody of certain client accounts based on the existence of standing letters of authorization (“SLOAs”) authorizing Baker Street to direct client assets from certain accounts to client-approved third parties. In such cases, the assets are maintained by independent, unaffiliated qualified custodians. In lieu of an annual custody examination, Baker Street meets certain prescribed regulatory requirements with respect to such accounts. Clients should be aware of their responsibility to verify the accuracy of the fee calculation submitted to the custodian by the Advisor, as the custodian will not determine whether the fee has been properly calculated. Investment Discretion Baker Street provides investment supervisory services on a discretionary or non-discretionary basis as stated in the investment advisory agreement. When a Client agrees to discretionary management, we will be responsible for asset allocation and selecting investment managers and funds. The Advisory Agreement between the Client’s and Baker Street allows the Advisor Limited Power of Attorney (“LPOA”) authority for discretionary and non-discretionary accounts. This LPOA grants Baker Street only trading and limited funds and fee disbursement authority. Other limitations, including investment restrictions, are those imposed in writing by the Client. Voting Client Securities The Advisor will not vote (by proxy or otherwise) in any matter for which a shareholder vote is solicited by, or with respect to, issuers of securities beneficially held in the Client’s account. With regard to all other matters for which shareholder action is required or solicited with respect to securities beneficially held by the Client’s account such as (i) all matters relating to class actions, including without limitation, matters relating to opting in or opting out of a class and approval of class settlements and (ii) bankruptcies or reorganizations, the Advisor affirmatively disclaims responsibility for voting (by proxies or otherwise) on such matters and will not take any action with regard to such matters. Financial Information The Advisor has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage Client accounts. 14 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 

Part 2B of Form ADV The Brochure Supplement 575 Market Street, Suite 600 San Francisco, CA 94105 BakerStreetAdvisors.com Updated: March 2024 This brochure supplement provides information about Jeffrey M. Bardini, Jeffrey W. Colin, Adam T. Elegant, Alexander G. Gannon, James E. Milligan, Ryan E. Murray, Heather L. Pelant, Annie E. Roth, Wendy A. Umphrey, Michael van den Akker, and Christopher J. Wilkens. It supplements the Advisor’s accompanying Form ADV brochure. Please contact the Advisor’s Chief Compliance Officer at 415.344.6184 if you have any questions about the Form ADV brochure or this supplement, or if you would like to request additional or updated copies of either document.  Table of Contents Jeffrey M. Bardini’s Biographical Information 3 Jeffrey W. Colin’s Biographical Information 4 Adam T. Elegant’s Biographical Information 5 Alexander G. Gannon’s Biographical Information 6 James E. Milligan’s Biographical Information 7 Ryan E. Murray’s Biographical Information 8 Heather L. Pelant’s Biographical Information 9 Annie E. Roth’s Biographical Information 10 Wendy A. Umphrey’s Biographical Information 11 Michael van den Akker’s Biographical Information 12 Christopher J. Wilkens’s Biographical Information 13 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 2  Completion of college level study or its equivalent is generally required of the Advisor's representatives. Additionally, a thorough knowledge of economic and financial principles, modern portfolio theory, optimization techniques as well as their application must be demonstrated. This knowledge may be acquired via business experience, education, and passage of securities examinations, attainment of professional designations or a combination thereof. Jeffrey M. Bardini’s Biographical Information Educational Background and Business Experience Year of Birth: 1981 Formal Education after High School: California Polytechnic State University – BS, 2005 Business Background for the Preceding Five Years: January 2021 to Present Managing Director, Baker Street Advisors, LLC April 2016 to December 2020 Vice President, Baker Street Advisors, LLC Disciplinary Information Mr. Bardini has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Bardini or of the Advisor. Other Business Activities Mr. Bardini is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Bardini does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all of the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 3  Jeffrey W. Colin’s Biographical Information Educational Background and Business Experience Year of Birth: 1963 Formal Education after High School: Northwestern University – BS, 1985 J.L. Kellogg Graduate School of Management – MBA, 1991 Business Background for the Preceding Five Years: October 2003 to Present Partner, Baker Street Advisors, LLC December 2002 to August 2003 Managing Director, Deutsche Bank Alex Brown May 2001 to October 2002 Managing Director, Robertson Stephens February 2000 to May 2001 Managing Director, myCFO, Inc. August 1991 to February 2000 Vice President, Goldman Sachs Disciplinary Information Mr. Colin has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Colin or of the Advisor. Other Business Activities Mr. Colin is not engaged in any other investment related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Colin does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 4  Adam T. Elegant’s Biographical Information Educational Background and Business Experience Year of Birth: 1973 Formal Education after High School: Washington University in St. Louis – Political Science, 1995 University of Colorado, Leeds School of Business – MBA, 1999 Business Background for the Preceding Five Years: January 2022 to Present Partner, Baker Street Advisors, LLC November 2019 to December 2021 Managing Director, Baker Street Advisors, LLC April 2014 to November 2019 Director, KKR & Co. Inc. April 2013 to March 2014 Vice President, Northern Trust August 1999 to April 2013 Vice President, Goldman Sachs Disciplinary Information Mr. Elegant has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Elegant or of the Advisor. Other Business Activities Mr. Elegant is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Elegant does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 5  Alexander G. Gannon’s Biographical Information Educational Background and Business Experience Year of Birth: 1989 Formal Education after High School: University of Notre Dame, BBA, 2011 Business Background for the Preceding Five Years: April 2023 to Present Managing Director, Baker Street Advisors, LLC January 2020 to April 2023 Vice President, Baker Street Advisors, LLC July 2016 to December 2019 Manager, Baker Street Advisors, LLC Disciplinary Information Mr. Gannon has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Gannon or of the Advisor. Other Business Activities Mr. Gannon is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Gannon does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 6  James E. Milligan’s Biographical Information Educational Background and Business Experience Year of Birth: 1961 Formal Education after High School University of Texas at Austin – B.S. Civil Engineering 1983 Stanford Graduate School of Business – Master’s in Business Administration 1987 Business Background for the Preceding Five Years January 2016 to Present Partner, Baker Street Advisors, LLC March 2011 to December 2015 Managing Director, Baker Street Advisors, LLC February 1999 to March 2008 Managing Director & Regional Manager Private Wealth Management (PWM), Goldman Sachs April 1997 to January 1999 Managing Director, Regional Manager (PWM), Goldman Sachs August 1987 to April 1997 Vice President and Private Client Advisor (PWM), Goldman Sachs Disciplinary Information Mr. Milligan has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Milligan or of the Advisor. Other Business Activities Mr. Milligan is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Milligan does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Mr. Milligan receives compensation as a lecturer at the Stanford University Graduate School of Business. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 7  Ryan E. Murray’s Biographical Information Educational Background and Business Experience Year of Birth: 1985 Formal Education after High School: University of Richmond – BA, 2007 Business Background for the Preceding Five Years: April 2023 to Present Managing Director, Baker Street Advisors, LLC September 2022 to April 2023 Chief Relationship Officer, Syon Capital, LLC September 2019 to September 2022 Vice President, Merrill Lynch & Co. July 2007 to September 2019 Vice President, Goldman Sachs & Co. Disciplinary Information Mr. Murray has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Murray or of the Advisor. Other Business Activities Mr. Murray is not engaged in any other investment related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Murray does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 8  Heather L. Pelant’s Biographical Information Educational Background and Business Experience Year of Birth: 1968 Formal Education after High School: University of Victoria – BA, 1991 University of Hawaii – MA, 1996 J.L. Kellogg Graduate School of Management – MBA, 2009 Business Background for the Preceding Five Years: January 2020 to Present Partner, Baker Street Advisors, LLC December 2016 to December 2019 Managing Director, Baker Street Advisors, LLC January 2003 to August 2016 Managing Director, BlackRock January 1997 to January 2002 Vice President, Morgan Stanley Disciplinary Information Ms. Pelant has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Ms. Pelant or of the Advisor. Other Business Activities Ms. Pelant is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Ms. Pelant does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 9  Annie E. Roth’s Biographical Information Educational Background and Business Experience Year of Birth: 1980 Formal Education after High School: University of California, Berkeley – B.A. Physics, 2004 Business Background for the Preceding Five Years: April 2023 to Present Managing Director, Baker Street Advisors, LLC January 2022 to April 2023 Senior Vice President, Baker Street Advisors, LLC July 2017 to January 2022 Vice President, Baker Street Advisors, LLC April 2013 to July 2017 Manager, Baker Street Advisors, LLC April 2011 to April 2013 Investment Associate, Wetherby Asset Management May 2004 to April 2011 Registered Client Service Associate, Technical Analyst and Investment Associate, UBS AG Disciplinary Information Ms. Roth has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Ms. Roth or of the Advisor. Other Business Activities Ms. Roth is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Ms. Roth does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 10  Wendy A. Umphrey’s Biographical Information Educational Background and Business Experience Year of Birth: 1971 Formal Education after High School: University of Michigan – BA, 1993 Business Background for the Preceding Five Years: January 2020 to Present Partner, Baker Street Advisors, LLC January 2017 to December 2019 Managing Director, Baker Street Advisors, LLC April 2007 to December 2016 Vice President, Baker Street Advisors, LLC Disciplinary Information Ms. Umphrey has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Ms. Umphrey or of the Advisor. Other Business Activities Ms. Umphrey is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Ms. Umphrey does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 11  Michael van den Akker’s Biographical Information Educational Background and Business Experience Year of Birth: 1952 Formal Education after High School: San Francisco State University – BA, 1976 Business Background for the Preceding Five Years: February 2004 to Present Partner, Baker Street Advisors, LLC October 2005 to April 2015 Director and Chair of the Asset/Liability Committee, New Resource Bank September 1999 to February 2004 Managing Director, myCFO, Inc. January 1985 to September 1999 Partner, Price Waterhouse, LLP Disciplinary Information Mr. van den Akker has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. van den Akker or of the Advisor. Other Business Activities Mr. van den Akker is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. van den Akker does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 12  Christopher J. Wilkens’s Biographical Information Educational Background and Business Experience Year of Birth: 1971 Formal Education after High School University of Wisconsin, Madison – BA 1993 Business Background for the Preceding Five Years March 2007 to Present Partner, Baker Street Advisors, LLC April 2003 to February 2007 Principal, VERITY Wealth Advisors, LLC April 1997 to April 2003 Director, Merrill Lynch & Co. April 1996 to April 1997 Associate, Barclays de Zoete Wedd Securities, Ltd. July 1993 to April 1996 Analyst, Goldman Sachs Disciplinary Information Mr. Wilkens has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Wilkens or of the Advisor. Other Business Activities Mr. Wilkens is not engaged in any other investment-related business and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Wilkens does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all the Baker Street Partners and Managing Directors, and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 13 

Item 1: Cover Page __________________________________________________________________________________________ BAKER STREET ADVISORS Independent. Customized. Focused. Form ADV Part 2A The Brochure (CRD #128066 / SEC #801-62370) 575 Market Street, Suite 600 San Francisco, CA 94105 T: 415.344.6180 www.BakerStreetAdvisors.com Updated: March 31, 2025 This brochure provides information about the qualifications and business practices of Baker Street Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 415.344.6180. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the United States Securities and Exchange Commission ("SEC") or any state securities authority or an offer of securities; please refer to the actual investment offering and related legal documentation for complete disclosures. Registration as an investment adviser does not imply a certain level of skill or training. Investments involve risk, including the possible loss of principal. An adviser's written and oral communications provide you with information to determine whether to retain their services. This brochure is on file with the appropriate regulatory authorities as required by federal and state regulations. Additional information about the Adviser or any of its affiliated persons who are registered or required to be registered as Investment Advisor Representatives of the firm is available on the SEC's website at www.adviserinfo.sec.gov.  BAKER STREET ADVISORS Independent. Customized. Focused. Item 2: Table of Contents __________________________________________________________________________________________ Item 1: Cover Page ...................................................................................................................................... 1 Item 2: Table of Contents ............................................................................................................................. 2 Item 3: Material Changes ............................................................................................................................. 3 Item 4: Advisory Business ............................................................................................................................ 4 Item 5: Fees & Compensation......................................................................................................................8 Item 6: Performance-Based Fees & Side-by-Side Management ............................................................... 14 Item 7: Types of Clients ............................................................................................................................. 14 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .......................................................... 14 Item 9: Disciplinary Information .................................................................................................................. 16 Item 10: Other Financial Industry Activities & Affiliations ........................................................................... 16 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ................... 17 Item 12: Brokerage Practices ..................................................................................................................... 19 Item 13: Review of Accounts...................................................................................................................... 23 Item 14: Client Referrals & Other Compensation ...................................................................................... 23 Item 15: Custody ........................................................................................................................................ 24 Item 16: Investment Discretion .................................................................................................................. 25 Item 17: Voting Client Securities ................................................................................................................ 26 Item 18: Financial Information .................................................................................................................... 26 2  BAKER STREET ADVISORS Independent. Customized. Focused. Item 3: Material Changes __________________________________________________________________________________________ Baker Street Advisors, Inc. reviews its Form ADV Part 2A brochure at least annually to confirm it remains current. In this item, we are required to summarize only those material changes made to our brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 28, 2024, we have the following material changes to report: Item 4: Services, Fees & Compensation Control Persons & Executive Officers Effective October 1, 2024, Christopher H. Gordon was promoted to Managing Director, and Jordan D. Kienzle started his new role as a Client Service Partner. Effective April 1, 2025, Michael van den Akker is no longer a Partner due to his retirement. Assets Under Management As of December 31, 2024, Baker Street's assets under continuous management totaled $17.8 billion on behalf of approximately 535 Clients. The following represents Client assets under management by account type: Account Type Assets Under Management Discretionary Non-Discretionary Total $ 17,800,000,000 $ 0 $ 17,800,000,000 Item 5: Fees & Compensation In this section, the Fee Schedule was updated to include an annual minimum fee of $25,000. For assets under $4 million, the fee will be 0.75%, with a minimum annual fee of $25,000. Clients with assets under management exceeding $4 million will incur an annual fee of 0.50% on the first $15 million. Enhancement to ADV Disclosures This Brochure was also amended to include increased disclosures, supplementary clarifying information on Baker Street's advisory practices, and aesthetic and formatting changes. While these changes may not necessarily be material, the enhancements are intended to clarify and better aid investors in understanding the firm's business model, procedures, and services. Full Brochure Availability We may amend this document at any time to reflect material changes in our business practices, policies, or procedures, as securities regulators require. Annually, within 120 days of the close of our fiscal year on December 31st, and as needed for any material changes, we will provide Clients - either electronically or in hard copy, with a new brochure or a summary of material changes from the previously supplied document along with an offer to deliver the full brochure upon request. Please retain this document for future reference, as it contains essential information about our advisory services and business. You may view our current disclosure documents at or the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either by our firm name, Baker Street Advisors, LLC or CRD #128066. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at T: 415.344.6180. 3  BAKER STREET ADVISORS Independent. Customized. Focused. Item 4: Advisory Business __________________________________________________________________________________________ Description of Firm Baker Street Advisors, LLC ("Baker Street" or "the Adviser") was founded in 2003. The firm, whose principal office and place of business is located at 575 Market Street, Suite 600, San Francisco, CA, is an investment adviser who has been registered with the United States Securities and Exchange Commission under the Investment Advisers Act of 1940 as amended ("Advisers Act"), since 2003. Principal Ownership Baker Street is directly owned by its Partners and Managing Members, each of which owns < 25% equity interest except for Watson Acquisition, LLC (Managing Member), which maintains > 50% equity interest. In April 2015, Affiliated Managers Group, Inc. ("AMG") acquired over 50% equity interest in the firm. As a result of this transaction, the Adviser converted from a California Limited Liability Company (“LLC”) to a Delaware LLC. AMG, a publicly traded asset management company (NYSE: AMG), also has equity interests in certain other investment management firms ("AMG Affiliates"). (Note: Further information on AMG and the AMG Affiliates is provided in Item 10: Other Financial Industry Activities & Affiliations.) Baker Street's indirect ownership is as follows: Affiliated Managers Group, Inc.(Series A Member, Manager & Sole Shareholder) holds a 50% ownership interest in AMG WP LP Holdings, Inc. (Limited Partner). AMG Wealth Partners, LP (Member) holds a 50% ownership interest in AMG Managers Group, Inc., and AMG WP LP Holdings, LLC holds a 50% ownership interest in AMG Wealth Partners, LP. AWG WP GP Holdings Corporation (the General Partner of AMG Wealth Partners, LP) is indirectly controlled by AMG Managers Group, Inc., which owns 50% of AWP GP Holdings Corporation. Advisory Business In this Brochure, the terms "we," "our," “the Adviser,” or "us" refer to Baker Street, and the terms "you," "your," and "Client" refer to you as either a current or prospective Client of our firm. The term "Employee" refers to Baker Street's Supervised Persons, which include the firm's Officers, Directors and Executive Officers ("Control Persons"), employees, and its Investment Professionals - the firm's licensed and registered Investment Advisor Representatives ("IARs") who are supervised, and approved by Baker Street to provide investment advice or advisory services on behalf of the Adviser, as required for their roles and Client base. Baker Street owes a fiduciary duty to its Clients as defined by applicable laws and regulations. As a fiduciary, the firm is committed to acting with loyalty, care, fairness, and good faith toward each Client. This commitment includes mitigating any potential conflicts of interest that may arise in the course of providing services. In delivering investment advice, we endeavor to exercise the highest degree of care, skill, prudence, and diligence that a prudent person acting in a fiduciary capacity would apply under similar circumstances. Applicable regulations require our registered investment professionals to obtain the necessary licenses and complete the required training to recommend specific investment products and services. Clients should be aware that their IAR's ability to recommend certain services, investments, or strategies may depend on the specific licenses or training they have completed. Additionally, IARs are only authorized to transact business or respond to Client inquiries in states and locations where they are properly licensed. For additional information about the individuals providing advisory services on our behalf, Clients should refer to their IAR's Form ADV 2B Brochure Supplement, a separate disclosure document provided alongside this brochure, prior to or at the time the advisory relationship begins. (If the Client did not receive this document, please contact us directly at 415.344.6180 to obtain a copy.) Non-Exclusive Relationship Baker Street's relationship with each Client is non-exclusive; in other words, we provide advisory services to multiple Clients, with investment strategies and advice based on each Client's specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each Client's specific financial situation, the advice we provide to one Client can differ or conflict with that provided for the same security or investment for another. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) 4  BAKER STREET ADVISORS Independent. Customized. Focused. Other Professional Service Provider Recommendations Baker Street may suggest the services of other professionals for implementation purposes, such as lawyers, accountants, insurance agents, and others. These professionals are engaged directly by the Client on an as-needed basis. Unless otherwise stated, Baker Street does not receive referral fees for such recommendations, and Clients are under no obligation to use any recommended services. If Clients choose to engage these professionals, they will enter into a separate agreement directly with the selected individual(s). Except where specifically indicated, Baker Street is not involved in the transaction and does not have the authority to accept Clients on behalf of any referred professional. Each referred professional has the right to decline any Client or prospective Client for any reason or without reason. In selecting a referred professional, the Client is responsible for reviewing and understanding the referred provider's separate contract, including any associated charges. The Client will be liable for these charges should they choose to engage the referred professional. The Client retains full discretion over all such implementation decisions and is under no obligation to accept or follow any recommendation from Baker Street. If a Client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against the engaged professional. Should any conflicts of interest arise concerning the recommendation of other professionals in the future, Baker Street will notify the Client accordingly. (See Item 10: Other Financial Industry Activities & Affiliations for additional information.) Client Responsibilities Baker Street's advisory services rely on the information provided by Clients. The Adviser cannot adequately fulfill its obligations and fiduciary duties to the Client unless the Client discloses an accurate and complete representation of their financial position and investment needs, submits any requested data or documentation in a timely manner, provides updates promptly upon changes, and otherwise fulfills their responsibilities under the Advisory Agreement. Baker Street will rely on the accuracy of the information supplied by the Client or on their behalf without further investigation; The Adviser is not obligated to verify information obtained from Clients or other professional advisors, including accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services provided changes, if previously provided information that might affect the management of their account occurs, or if any earlier provided data becomes inaccurate. The Client or their successor shall also promptly notify us in writing of the Client's dissolution, termination, merger, or bankruptcy if the Client is not a natural person or of the occurrence of any other event that might affect the validity of their Advisory Agreement or our authority under the Agreement. Baker Street reserves the right to terminate any Client engagement where the Client has willfully concealed or failed to provide pertinent information material to the advisory services to be rendered or to their individual or financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Advisory Agreement Baker Street's advisory services are designed to address the specific needs of each Client, as outlined in the applicable written Client contract, whether the Investment Advisory Agreement ("Advisory Agreement") or Professional Services Agreement (collectively, the "Agreement") - depending on the services selected. Each Agreement will outline the scope of services, contract terms, advisory fees, the formula for calculating such charges, and the type of investment management authority granted. Additionally, the Agreement will specify whether any written reports or electronic plans will be provided. The final advisory fee structure for the selected service will be clearly documented in the executed Agreement. IARs are limited to providing only the services specified in the respective Agreements and must adhere to the Client's stated objectives, limitations, and restrictions, as applicable. To engage Baker Street's advisory services, Clients must complete and execute the appropriate Agreement for the selected service. Clients may engage us for additional services at any time. Once established, an Agreement may not be assigned, as defined under the Advisers Act, without the Client's consent, as specified therein. 5  BAKER STREET ADVISORS Independent. Customized. Focused. Clients should consult with their IAR and the applicable Agreement and fee schedules for additional information regarding each service. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Advisers Act shall not be considered an assignment. For further information regarding advisory service fees and account management style, refer to Item 5: Fees & Compensation and Item 16: Investment Discretion.) Investor Profile & Client Suitability Baker Street is an investment advisory firm dedicated to Client engagement and personalized financial guidance. We provide tailored investment advice, advisory services, and wealth management technology designed to strive to meet the unique needs of each Client. At the outset of the advisory relationship, the IAR will conduct a comprehensive assessment of the Client's financial situation. This evaluation involves personal discussions, diagnostic questionnaires, and other tools provided by the Adviser. Key factors such as investment goals, financial objectives, risk tolerance, liquidity and income needs, time horizon, and market expertise will be evaluated. Additionally, the Client's income, expenses, and existing investments will be reviewed to form a clear understanding of their overall financial landscape. Further pertinent information will be gathered, including detailed financial data such as assets, liabilities, and portfolio statements. This data will serve as the foundation for crafting customized investment plans and recommendations tailored to the Client's specific financial situation. Based on this comprehensive profile, the IAR will recommend an appropriate advisory service for the Client. Depending on the selected advisory service, a strategic investment recommendation will be formulated, which includes the development of an asset allocation strategy. This strategy will take into account the Client's financial objectives, risk tolerance, and personal preferences. The goal is to establish realistic, measurable financial targets and create an investment strategy that supports both short-term and long-term financial objectives. The executed Agreement will clearly outline the specific advisory services to be provided, along with the agreed-upon fee structure, ensuring transparency and mutual understanding of the terms. Types of Advisory Services Baker Street provides the following advisory services: Investment Supervisory Services 1. 2. Professional Services (to include, but not limited to, Expense Management, Consulting and Financial Planning) Investment Supervisory Services Baker Street provides investment supervisory services primarily on a discretionary basis to a variety of Clients. Services are provided in accordance with the Baker Street Advisory Agreement with account supervision guided by the Client's stated investment objectives. We develop strategic plans for our Clients by assessing their long-term and short-term financial needs, objectives, risk tolerance or aversion, and tax status. These plans are crafted using the information they provide, including financial records, responses to questionnaires, and insights gathered during personal interviews. Each investment portfolio is tailored to align with the Client’s specific goals and objectives, following a comprehensive evaluation of their financial circumstances. Subsequently, we create an Investment Policy Statement (“IPS”) and an asset allocation plan for each Client based on a thorough analysis of their financial situation and investment objectives. The IPS typically outlines their investment goals, restrictions, regulatory requirements, risk tolerances, and other pertinent factors. Upon receiving the Client’s approval, we will proceed to implement the IPS strategy as appropriate. Professional Services Professional services may include expense management, consulting, financial planning, estate and trust services, risk management and insurance services and philanthropy services, among others. (Note: Estate and trust services may require the Client to engage independent legal counsel. Baker Street does not provide legal advice or draft legal documents.) 6  BAKER STREET ADVISORS Independent. Customized. Focused. To engage in any of these services, clients will execute a Professional Services Agreement, which will define the scope of services to be provided and the agreed-upon fees, which will be determined depending on the complexity and scope of the planning process. The duration and cost will be specified in the executed services Agreement. Financial plans and recommendations are based on the Client's financial situation as disclosed at the time of Agreement execution. The timeline for completing an initial financial plan may vary depending on the Client’s responsiveness and the timely submission of all required information and supporting documents. If the Client receives a written financial plan, the plan will not include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, it shall be the Client's responsibility to obtain them from one or more third parties. As financial planning is inherently a discovery process, where new information may surface throughout the course of analysis, should discrepancies arise during this process and the Client’s circumstances differ significantly from the initial disclosures, the Client can be subject to a revised fee. In such cases, Clients will be notified promptly of any necessary changes to the engagement's scope, and no additional work will be undertaken until they approve the revised fee structure. Clients may request updates or additional reviews, which may incur additional fees at the firm’s current hourly rate. (See Item 5: Fees & Compensation for further information.) Types of Investments Our investment recommendations primarily involve independent third-party investment advisers, mutual funds, exchange-traded funds ("ETFs"), and private investments. We do not offer proprietary investments. All investments we recommend have undergone a rigorous due diligence process and are continuously monitored by our Investment Strategy Group. The investment advice provided to Clients is not limited to specific products or asset classes. However, we generally refrain from recommending the direct purchase or sale of individual, non-pooled securities. Instead, we offer comprehensive investment and portfolio management advice across a broad spectrum of asset classes, ensuring that our recommendations are tailored to each Client’s unique goals and needs. We may also guide on existing holdings and suggest strategies for portfolio diversification when appropriate. While we do not engage in market timing, we may recommend increasing cash holdings when it aligns with the Client's overall portfolio strategy. Tailored Advisory Services Baker Street offers a comprehensive suite of services to all Clients, though some may require only limited services based on the nature of their investments. In such cases, limited services are offered at our discretion, as outlined in the Client's written Agreement, which will contain applicable terms and fee schedules. Baker Street reserves the right to advise on any investment product deemed suitable for a Client's circumstances, needs, and objectives, which may include advising on those already held in a Client's portfolio at the outset of the advisory relationship. Additionally, when appropriate, we may recommend other securities to help diversify a portfolio. (For further information, see Item 5: Fees & Compensation and Item 8: Methods of Analysis, Investment Strategies & Risk of Loss.) Client Imposed Restrictions Clients have the right to impose restrictions on the types of securities or specific securities in which they wish to invest based on personal preferences, values, or beliefs. Such restrictions must be provided to the Adviser in writing and accepted prior to implementation. Clients may modify or amend these restrictions by submitting updated written instructions. Restrictions will only take effect once formally accepted. Baker Street will make reasonable efforts to adhere to Client-imposed investment guidelines, including any reasonable limitations consistent with standard industry practices. However, Clients should be aware that such restrictions may influence the performance of their accounts, potentially resulting in performance variations - both positive and negative - compared to similar accounts without such limitations. Additionally, these restrictions could hinder the achievement of a Client's specific financial objectives. Upon receipt of written restrictions, Baker Street will assess the feasibility of the request, ensure that the Client's expectations are appropriately managed, and confirm that the Client understands the potential consequences of the imposed restrictions. 7  BAKER STREET ADVISORS Independent. Customized. Focused. Baker Street reserves the right to reject specific restrictions or terminate the advisory relationship if such restrictions cannot be reasonably accommodated. In no event, irrespective of the advisory service provided, shall Baker Street be obligated to make any investment or engage in any transaction that, in its reasonable and good faith judgment, would violate any applicable federal or state law or regulation. Wrap Fee Programs A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a Client's Account are charged for investment supervisory services, which may include portfolio management or advice concerning the selection of other investment advisers and the execution of Client transactions. Baker Street does not offer a wrap fee program as part of its advisory services. Assets Under Management As of December 31, 2024, Baker Street's assets under continuous management totaled $17.8 billion on behalf of approximately 535 Clients. The following represents Client assets under management by account type: Account Type Assets Under Management Discretionary Non-Discretionary Total $ 17,800,000,000 $ 0 $ 17,800,000,000 Item 5: Fees & Compensation __________________________________________________________________________________________ Adviser Fee Structure & Compensation Overview Advisory Clients agree to pay either a recurring, asset-based advisory fee based on assets under management ("AUM") or a flat fixed, one-time or hourly fee arrangement depending on the advisory services selected, calculated and billed according to the Fee Schedules schedules reflected herein, with any applicable refunds addressed as specified in the Client's finalized written and executed Advisory Agreement. Fee Negotiation Availability Advisory fees are negotiable up to the maximum annual rates specified in the Client's written Agreement, subject to approval by Baker Street. The Adviser reserves the right to adjust fees based on factors such as the Client's relationship with us, assets under management, account composition, the complexity of their situation, and anticipated future earning capacity. Fees may also be negotiated for Clients requiring specialized investment services or for family members of adviser employees. In some cases, accounts held by the Client, family members, or related parties may be aggregated for fee calculation purposes. While we seek to facilitate advantageous Agreements for Clients, to the extent fees are negotiable, some Clients can pay higher (more) or lower (less) fees than other Clients for services than if they had contracted directly with another provider. Lower fees for comparable services can sometimes be available from different sources. Clients are responsible for any tax liabilities arising from transactions. Regardless of fee negotiation availability, under no circumstances will a Client be required to pre-pay any advisory fee more than six months in advance in excess of $1,200. Investment Supervisory Services Fees Compensation for investment supervisory services is derived as fee income, calculated as a percentage of a Client's assets under management. The compensation structure is clearly explained and agreed upon with the Client prior to the commencement of any services. Our services - which include developing and implementing an investment policy and objectives, monitoring a Client's investment performance, selecting and overseeing Investment Managers, and providing quarterly reports, are compensated as follows: 8  BAKER STREET ADVISORS Independent. Customized. Focused. Fee Schedule Assets Under Management Annual Fee $0 - $4,000,000* $4,000,001 - $15,000,000 $15,000,001 - $25,000,000 $25,000,001 - $50,000,000 $50,000,001 - $75,000,000 $75,000,001 - $100,000,000 $100,000,001 - $200,000,000 $200,000,001 - $500,000,000 $500,000,001 - $1,000,000,000 Above $1,000,000,000 0.75%* 0.50% 0.40% 0.30% 0.20% 0.10% 0.07% 0.05% 0.03% 0.01% *Note: This tier does not apply to Clients with greater than $4,000,000 under Management. • For assets under $4 million, the fee will be 0.75%, with a minimum annual fee of $25,000. • Clients with assets under management over $4 million will incur an annual fee of 0.50% on the first $15 million. Professional Services Fees Fees for Professional Services are based on a retainer, an hourly rate of $250 to $750 or an annual fee as agreed upon between Baker Street and the Client. Hourly fees are negotiable based on the nature and complexity of the services to be provided and the overall relationship with us. We provide you with an estimate for total hours and overall costs for your review and approval prior to engaging us for these services. Advisory Fee Calculation, Billing & Refunds Fees for Clients who do not have accounts at SEI Investments Company (“SEI”) are billed quarterly in advance of one-fourth of the annual rate based on a percentage of the Client's assets under management at the end of the calendar quarter. Investment advisory services begin with the effective date of the Advisory Agreement, which is the date the Client signs the Agreement. For that calendar quarter, fees will be adjusted pro-rata based on the number of calendar days in the calendar quarter for which the Agreement was effective. Fees for Clients who have accounts at SEI are billed quarterly in arrears of one-fourth of the annual rate based on a percentage of the Client's assets under management at the end of the calendar quarter. Investment advisory services begin with the effective date of the Advisory Agreement, which is the date the Client signs the Agreement. For that calendar quarter, fees will be adjusted pro-rata based on the number of calendar days in the calendar quarter for which the Agreement was effective. Clients that have assets under management of less than $4 million will be subject to an annual fee of .75%, with a minimum annual fee of $25,000, calculated as described previously. Clients that have assets under management of over $4 million will be subject to an annual fee of .50% on the first $15 million of assets under management. The portfolio value upon which the percentage fee is based will include the current fair market value of all of the Client's investments managed by Baker Street unless specifically excluded as mutually agreed upon by the Advisor and the Client. Any exclusions will be documented in the Agreement. These investments may consist of mutual funds, exchange-traded funds, limited partnerships, fixed and variable annuity accounts, stocks, bonds, and other securities selected by the Investment Managers. While the Clients' custodians readily price the majority of holdings in Client portfolios, certain investments, such as private funds, may require Baker Street to obtain valuations from the fund Investment Managers, utilize the investment cost, or utilize fair valuation based on estimates received from the Investment Managers. As such, valuation utilized for the purpose of reporting and fee calculation may differ from that reflected on a Client's custodial statement. Clients should be aware of their responsibility to verify the accuracy of the fee calculation submitted to their custodians by the Adviser, as the custodian will not determine whether the fee has been properly calculated. 9  BAKER STREET ADVISORS Independent. Customized. Focused. Method of Advisory Fee Payment Clients have several options to pay their Baker Street advisory fees and will indicate their preference on the Agreement they execute with us. The Client may choose to have our advisory fees (1) directly debited from their account assets held at their custodian or (2) billed and be responsible for remitting their payment themselves. The process for each payment option follows: Directly Debited Fees - Clients who wish to have their fees directly debited will provide written limited authorization instructions to their custodian, directing them to allow Baker Street to withdraw any advisory fees due. The limited authorization will authorize the Adviser to invoice the custodian directly for the Client's advisory fees and instruct the custodian to debit any fees from the Client's custodial account automatically. After each advisory fee payment transfer, the written instructions will also request that the custodian provide a "transfer of funds" notice to the Client at their custodial address of record. The Client may provide these instructions on the Qualified Custodian's form or separately. The custodian will maintain actual custody of the Client's assets. Baker Street will calculate the advisory fees owed based on the terms specified in the Client's Agreement, and the custodian will remit payment to us as instructed. Upon receiving Baker Street’s instructions, the Qualified Custodian will automatically deduct and pay us from the Client’s custodial account the fee amount due for the billing period. The account custodian does not verify the accuracy of our advisory fee calculation. Regardless of the market performance of the portfolio during the fee period, fees will be assessed as outlined in the Agreement. Baker Street’s account advisory fee will be payable first from free credit balances, money market funds, or cash equivalents if any, and second from liquidating a portion of the Client’s securities holdings. Additionally, the custodian will send the Client a statement reflecting the fee amounts paid, which will be delivered to the Client’s address of record or another authorized address designated in writing by the Client. Baker Street may also charge an alternative payment method on file instead of deducting it from a Client’s custodial account. Billed Fees - Clients who prefer to be directly billed must authorize this payment method in writing as part of their Agreement. Under this arrangement, Clients will receive advisory fee invoices from us for the advisory fees due, with payment due upon receipt. Clients will make their payments directly to Baker Street via check, ACH or wire transfer. Under no circumstances will such advisory fees be deducted from a Client’s custodial account(s) unless directed otherwise by the Client in writing. Payment for non-investment-related services may be made by check, ACH or wire transfer. (Note: Checks should never be made out to any individual representative of the Adviser.) Please also note that when authorized by the Client to debit advisory fees from Client accounts, under the SEC’s Custody Rule, Baker Street is deemed to have custody of Client assets to the extent that the adviser has the authority to instruct custodians to withdraw these fees directly from the Client's account. As such, we are required to comply with all applicable requirements, including providing Clients with account statements and ensuring proper safeguards are in place. Baker Street encourages Clients to promptly review any statements received from their custodian(s) to ensure the accuracy of account transactions. Clients are advised to compare their accounts’ investment performance with the relevant benchmark for the types of investments held, as well as any reports or information we provide. We strongly recommend that Clients also compare their custodian account statements with any portfolio reports or data we supply upon receipt. Discrepancies may arise between our reports and custodian statements due to differences in accounting procedures, reporting dates, or valuation methodologies applied to specific securities. Should a Client identify any discrepancies between our reports and custodian statements, they are encouraged to contact both us and their custodian directly. If a Client does not receive statements directly from the custodian, we recommend reaching out to the custodian in addition to notifying their Advisor. In all instances, Clients should contact us promptly with any concerns regarding account activity before the next billing cycle and provide written follow-up. 10  BAKER STREET ADVISORS Independent. Customized. Focused. Account Additions, Withdrawals & Terminations Clients can make additions to their Baker Street accounts in cash or securities at any time. The Adviser reserves the right to liquidate any transferred securities or decline to accept particular securities into the Client's account, according to the type of authority granted to us. If the Adviser liquidates transferred securities, Clients can be subject to additional fees such as transaction fees, other fees assessed at the mutual fund level such as contingent deferred sales charges, and tax ramifications. Clients can make withdrawals from their Baker Street accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures and costs. Additionally, if the Client transfers their account to another firm, they may pay an outgoing account transfer fee to the Custodian. Generally, terminations of advisory services may be made without penalty by providing written notice within five (5) business days of the Agreement's execution date. Thereafter, the Agreement will continue in effect until either party terminates following the terms of the Agreement through similarly provided written notice. Termination shall become effective on the business day the written notice is received by the other party. (Note: A "business day" is defined as any day when the New York Stock Exchange is open for trading.) Should the Client be invested in a private fund, separate account manager or other vehicle, Baker Street will provide contact information for that Investment Manager so that the Client can determine with the Investment Manager if the Client's funds will be/could be redeemed or if the Client will continue to work with that Investment Manager or remain invested in the particular investment vehicle. Termination of the Agreement will become effective upon receipt of notice from the Client and will not affect the following: • • • the validity of any actions previously taken by the Adviser under the Agreement, the liabilities or obligations of the parties arising from transactions initiated prior to the termination, and the Client's obligation to pay any management fees or other fees due, pro-rated through the termination date. The termination of investment-related services will not affect any investments in securities or insurance products made by the Client based on the Adviser's recommendations. These investments will remain subject to the terms of their respective offering memoranda or contracts. Upon receipt of a termination notice, the fees charged for advisory services will be pro-rated. The Adviser will initiate the process of delivering cash and/or securities according to the Client's instructions. If securities are liquidated, the Client may incur liquidation fees or contingent deferred sales charges. Market conditions at the time of liquidation may result in a loss, and additional fees may be imposed by the custodian or broker-dealer involved in the liquidation process. If the Client holds alternative investments or illiquid securities, they may be subject to specific redemption schedules, which could delay the process. Upon termination of investment-related services, the Client's funds will remain in their positions as of the termination date. The Adviser will have no further responsibilities regarding the account(s) or positions held within those accounts. Clients may not be able to liquidate or redeem illiquid investments immediately, and some illiquid investments may not be transferable to other advisory firms. Other Fees & Expenses Baker Street's advisory fees are separate and distinct from other costs and expenses Clients may incur in connection with their accounts. A list of some of these additional fees and costs includes, but is not limited to, the following: Mutual Funds, ETFs & Pooled Investment Vehicle Fees Mutual funds generally offer multiple share classes available for investment based on specific eligibility and/or purchase requirements. If such investments are selected for a Client's account, the Client and all other shareholders will pay an advisory fee to the funds' investment advisers. In addition to those underlying advisory fees, the Client will bear a proportionate share of the fund's expenses, including 12b-1 fees and shareholder sub-accounting and distribution costs. Each offering prospectus will describe the offering's complete fees and expenses, which can vary depending on the share class. Fee and internal expenses can be higher or lower depending on the selected share class. Certain funds do not charge a transaction fee but have higher internal expenses. Choosing funds with higher fees and costs can adversely impact an account's long-term performance. The appropriateness of a particular fund 11  BAKER STREET ADVISORS Independent. Customized. Focused. share class selection depends upon several considerations. Further, not all funds and share classes offered to the public are available through us, which a Client might otherwise be eligible to purchase. Clients should consider these and our investment fees to fully understand the total amount paid when evaluating the advisory services provided. Before recommending this type of purchase, an analysis will occur to determine whether the recommended fund share class is in the Client's best interest. When recommending these investments, it is our policy to consider all available share classes and select and recommend, whenever possible, that Clients invest in the lowest cost share class available based on the Client's needs and various other factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges and availability, among others. (For example, in addition to retail share classes - typically Class A, B, or C shares, mutual fund companies may offer institutional or other share classes specifically designed for purchase by investors who meet particular eligibility criteria. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund.) Therefore, in most cases, recommendations will be for institutional / advisers share classes with the lowest expense ratios. These are less expensive than other share classes and are usually available to investors in qualified fee- based adviser programs or accounts meeting specific minimum investment requirements. When deemed appropriate for an investor's specific situation, recommendations may also include selecting or holding a mutual fund share class that charges higher internal expenses than other available share classes for the same family. For share classes transferred in from other institutions, as soon as practicable upon receipt, an evaluation will occur on whether more appropriate share classes may be available for the Client to exchange at no cost and recommend that the Client switches to a lower-cost share class or recommend liquidating the existing holdings, which could result in the Client having to pay contingent deferred sales charges, or other redemption fees and tax implications. Despite such considerations, Clients should not assume they will be invested in the share class with the lowest possible expense ratio. Expenses for Private Fund Investments Clients investing in private funds, including hedge funds, private equity funds, and funds of funds, may incur expenses related to the pooled investment vehicle. These may include audit, legal, custodial, and other associated fees. Clients should refer to the private placement memorandum or limited partnership agreement for a detailed description of any additional expenses incurred. Fees Charged by Custodians & Other Financial Institutions In addition to the above, Clients should also be aware that our advisory fees are exclusive of bank, custodial or brokerage fees, commissions, trading and transactional costs, liquidation/transfer/termination fees, costs associated with certificate delivery or dealer profits, taxes, duties, and other governmental charges on brokerage accounts and securities transactions, wire and other transfer fees, mark-ups, mark-downs, regulatory fees, and other costs and expenses for the trades conducted in their custodial accounts. Clients must pay the price of the services provided by their custodian for arranging for the receipt and delivery of securities that are purchased, sold, borrowed or loaned for their account; making and receiving payments concerning account transactions and securities; maintaining custody of account securities and cash, receiving dividends, and processing exchanges, distributions, and rights accruing to the Client's account, among others. The custodian may be compensated through commissions or other transaction-based fees for securities transactions executed through the custodian (or its affiliates), asset-based fees for investments settled into the custodian's accounts, or both. Client custodial costs can also include transactions in foreign securities and execution on foreign stock exchanges, resulting in foreign or other transaction expenses and costs associated with international exchange transactions. Additional securities charges can be incurred and will vary considerably based on individual portfolio construction. Some other customary fees and expenses Clients can pay to other parties in connection with their accounts can include but are not limited to: Margin Interest - the interest the Client pays to a custodian/broker-dealer on loans to finance the purchase or sale of securities or securities in their investment account. The interest rate charged and other information about the loan, including how interest is calculated and other disclosures of risk and liability, 12  BAKER STREET ADVISORS Independent. Customized. Focused. will be described to the Client in the separate margin account agreement the Client executes with their custodian/broker-dealer. Fees for advice and execution on these securities are based on the total asset value of the account, which includes the value of the securities purchased on margin. While a negative amount may be shown on a Client's statement for the margined security due to a lower net market value, the fee amount charged by the Adviser for our advisory services is based on the absolute market value of the Client's account. To calculate an account's net asset balance, we deduct the amount of any outstanding margin balances from the account's total gross asset balance but do not deduct the amount of any outstanding non-purpose loan balances. This means if a Client chooses to loan their securities, we will only charge the fee on the net value of the account (i.e., we will discount the net margin balance). Using margin can also result in interest charges and all other fees and expenses associated with the security involved, and Securities Execution Transaction Fees - as noted previously, these are the fees charged by a clearing broker-dealer to an introducing broker-dealer and passed through to the Client for payment relating to the purchase and sale of securities in their investment account. A schedule of charges relating to the purchase and sales by type of security is provided to the Client by each account's custodian/broker-dealer of record, as well as any changes or updates to such fee schedules. The exact fees and terms of each custodian's services are described in the Agreement the Client will execute with their account custodian. (Refer to Item 12: Brokerage for additional information.) The Client should understand that all fees paid for our advisory services are separate and distinct from the asset- based management fees charged by the managers of mutual funds, ETFs, and pooled investment vehicles in which the Client invests, as well as any additional fees discussed herein. Baker Street does not receive any portion of these fees, commissions, costs, or expenses; these fees are in addition to and exclusive of our advisory service fees. Furthermore, we do not reduce or offset our advisory fees by any 12b-1 fees or sales-related compensation received from custodians, brokers, mutual fund companies, or insurance companies, whether resulting from a Client's purchase or sale of securities, insurance, or other investment products, or the value of the Client's account, free credit balance, margin account balance, or retirement account balances. Unless otherwise specified in the Agreement, Clients will be subject to our advisory fees in addition to the fees and expenses outlined above, based on the type of advisory service selected and the portfolio investments held, and are responsible for paying all applicable third-party fees. Fees & Compensation Evaluation To fully understand the total costs associated with their account, Clients are responsible for reviewing and comprehending not only this document and their Agreement with Baker Street but also any offering documents, prospectuses, disclosures, and other legal materials provided by their custodian or relevant securities products. These documents outline the fees, costs, expenses, commissions, and other pertinent information regarding securities transactions in the Client's investment account, as well as all fees charged by Baker Street, the custodian, the broker-dealer, and other applicable parties based on the type of account established. When evaluating the overall costs and benefits of our advisory services, Clients should consider not only our advisory fees but also both direct and indirect costs to fully understand the total expenses and assess the value of our services and the recommended investment products. We do not represent that our products or services are provided at the lowest cost. Our advisory fees and associated service expenses may be higher than those charged by other advisers or financial services firms for similar services. Clients have the option to obtain the same or similar products or services at a lower cost from different providers and may choose whether to act on our recommendations. Clients may purchase recommended investment products through any broker or agent, including those not affiliated with Baker Street. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss, Item 10, Financial Industry Activities and Affiliations, and Item 12: Brokerage Practices for additional information about the fees associated with our advisory service offerings.) 13  BAKER STREET ADVISORS Independent. Customized. Focused. Item 6: Performance-Based Fees & Side-by-Side Management __________________________________________________________________________________________ Performance-based fees are calculated based on a percentage of the capital gains or capital appreciation of a Client’s account. This fee structure is contingent upon the performance of the account, aligning the advisor's compensation with the success of the investment strategy. Side-by-side management refers to the practice of simultaneously managing accounts that are subject to performance-based fees alongside accounts that do not incur such fees. This approach requires careful consideration to ensure that the interests of all Clients are managed fairly and in accordance with applicable regulatory requirements. Baker Street does not accept performance-based fees or participate in side-by-side management. However, some Investment Managers or funds we recommend may charge performance fees. Item 7: Types of Clients __________________________________________________________________________________________ Types of Clients Baker Street primarily provides investment supervisory services to high-net-worth individuals and associated trusts, estates, charitable organizations, pension and profit-sharing plans, and other legal entities. Account Minimums Baker Street requires a minimum account size of $5,000,000; however, the Adviser has the discretion to waive the account minimum. Clients should note that certain investment products may have their own minimum fees or asset requirements, which are separate from our account minimums. These requirements are determined by the product's characteristics, not by our policies. Clients are advised to review relevant disclosure materials and consult with their Financial Intermediary to understand the applicable minimum requirements before and during the investment process. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss __________________________________________________________________________________________ Methods of Analysis & Investment Strategies Baker Street allocates (and/or recommends that the Client allocate) the Client's investment assets among Investment Managers and funds in accordance with the Client's designated investment objectives. In such situations, the Investment Managers (or, in the case of funds, the fund Investment Managers) shall have day-to- day responsibility for the active discretionary management of the allocated assets. The Adviser will provide the names of the Investment Managers selected from the Investment Manager search lists after considering the compatibility of the Investment Managers' investment philosophy, minimum investment requirements and other factors with the Client's investment objectives, risk tolerances and other Client criteria. As a general matter, Baker Street expects that the factors that will be used to determine the names of Investment Managers and funds to be included on the Investment Manager and fund search lists will consist of, but will not necessarily be limited to, reputation, management strength, performance record, philosophy, the continuity of management, service to Clients, minimum dollar investment requirement, and fees. This determination is facilitated through a proprietary quantitative analysis, in-person meetings, and statistical screening prior to the engagement of any Investment Manager or the selection of any fund. In addition, periodic performance and logistical updates are conducted in order to confirm that the Investment Manager or fund continues to fulfill a Client's mandate and goals. Although the Investment Managers and/or fund Investment Managers shall have day-to-day responsibility for the active discretionary management of our Clients' allocated assets, Baker Street shall continue to render investment advisory services to each Client relative to the ongoing monitoring and review of account performance, asset allocation and Client investment objectives. Risks of Loss & Other Types of Risk Clients should be aware that investing in securities involves the risk of loss, which they must be prepared to bear. Past performance is not indicative of future results, and the value of assets may fluctuate, potentially being worth more or less than the initial investment. The degree of risk varies depending on the type of investment. 14  BAKER STREET ADVISORS Independent. Customized. Focused. Baker Street does not guarantee that a Client's financial goals and objectives will be achieved, as the perception of financial loss may differ among Clients and is influenced by various risks, each of which impacts the probability and magnitude of potential losses. There is no guarantee that any services or analytical methods provided will predict future outcomes, accurately identify market trends, or protect against losses during market corrections or declines, that any investment strategy or asset allocation will meet Client expectations, or that past performance is indicative of future results. Investments are subject to numerous risks, and no strategy can guarantee profitability. Furthermore, no service or strategy provided by Baker Street can ensure specific tax or legal outcomes. The following list of general risks, although not exhaustive, provides a general overview of common risks that prospective Clients should carefully consider before engaging our services. Clients are also advised to thoroughly review all relevant disclosure brochures, legal documents, and offering materials, including those pertaining to the investment vehicles or strategies being recommended. Note: Items are presented alphabetically for ease of reading, not in order of importance Cybersecurity Risk - With the increased use of technologies to conduct business, Baker Street is susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyber incidents impacting Baker Street can cause disruptions and impact business operations, potentially resulting in the inability to transact business, financial losses, violations of applicable privacy and other laws, regulatory fines, penalties or reputational damage. While Baker Street has established a business continuity plan and risk management systems intended to identify and mitigate the risks associated with cyber-attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Furthermore, Baker Street cannot control the cybersecurity plans and systems put in place by third-party service providers, including recommended Investment Managers and issuers in which Client portfolios invest. Clients could be negatively impacted as a result. Independent Investment of Each Portfolio Fund - Each Investment Manager and fund will generally invest completely independently of one another and may, at times, hold economically offsetting positions. To the extent that Investment Managers and funds hold such positions, Client accounts may not achieve any gain or loss despite incurring fees and expenses in connection with such positions. Intrinsic Risks of Investing in Securities - An investment in individual securities or a portfolio of securities could cause a loss of money. The individual investments selected by Baker Street and the Investment Managers should be deemed speculative investments and are not intended as a complete investment program. The Adviser cannot give any guarantee that any Client will achieve the Client's investment objectives or that any Client will receive a return of the Client's investment. Investment Manager Risk - All investing involves risk of loss, and the investment strategy offered by Baker Street could lose money over short or even long periods. Additionally, Baker Street relies on the investment expertise and day-to-day management of investments to selected Investment Managers, subjecting Clients to manager risk. The investment performance of each Client's portfolio is affected by the investment performance of the underlying securities in which the portfolio invests, as selected by the Investment Managers. The ability of the portfolio to achieve its investment objective depends on the ability of the underlying securities to meet the Client's investment objectives and the allocation of the portfolio's assets among the underlying securities. There can be no assurance that the investment objective of each Client account or any underlying securities will be achieved. Through its investments in underlying securities, as selected by Investment Managers, each Client's account is subject to the risks of the underlying securities' investments and can experience losses. Certain risks of the underlying securities' investments are described below. Market Risk - Even a long-term investment approach cannot guarantee a profit. Economic, political, and issue-specific events will cause the value of securities and the funds that own them to rise or fall. Because the value of the Client's investments will fluctuate, there is the risk that the Client will lose money. Multiple Levels of Fees & Expenses - By investing with Investment Managers and funds, Clients bear Baker Street fees as well as Investment Manager and fund fees and, in some instances, expenses. Thus, Baker Street Clients may be subject to higher fees than if the Client invested directly with an Investment Manager 15  BAKER STREET ADVISORS Independent. Customized. Focused. or in a fund. In addition, certain private funds may be subject to a performance-based fee or allocation, irrespective of the performance of other portfolio funds. Generally, fees payable to private funds' Investment Managers will range from 0.20% to 3.25% (per annum). In addition, certain Investment Managers for private funds charge an incentive allocation or fee generally ranging from 10% to 25% of a private fund's net profits or realized return. The performance-based compensation received by an Investment Manager to a private fund may also create an incentive for that Investment Manager to make investments that are riskier or more speculative than those they might have made in the absence of the performance-based allocation. Such compensation may be based on calculations of realized and unrealized gains made by the Adviser without independent oversight. Risks of Specific Securities Utilized While we generally employ investment strategies aligned with domestic and international equity markets, higher- risk strategies may be used in specific cases. In such instances, our practice is to provide enhanced communication to Clients regarding the specific risks associated with the securities in the portfolio prior to implementation. Clients should understand that all investments carry risk, including the potential for losses that may exceed the initial principal invested, along with any gains, particularly if markets move unfavorably for the Client. Past performance is not indicative of future results. Additionally, Clients may forgo potentially more favorable returns by not considering alternative securities or commodities. Investments may experience both short- and long-term losses, and Clients should expect fluctuations in account value and returns similar to the overall performance of the stock and bond markets. Clients should only invest if they are able to bear such risks. Before acting on any analysis, advice, or recommendations, Clients are strongly encouraged to consult with their legal, tax, and other financial professionals to assess the suitability of any investment strategy based on their circumstances. Any inquiries regarding risks, fees, and costs should be directed to the Client’s IAR. Item 9: Disciplinary Information __________________________________________________________________________________________ Legal or Disciplinary Events Disclosure Registered investment advisers are obligated to disclose all material facts concerning any legal or disciplinary events that may be relevant to a Client’s or prospective Client’s assessment of the investment adviser or the integrity of its management. Neither the Adviser nor any member of Management has been involved in any legal or disciplinary events over the past 10 years that would be material to a Client’s evaluation of the firm or its personnel. Item 10: Other Financial Industry Activities & Affiliations __________________________________________________________________________________________ Baker Street is an independent registered investment adviser. The firm offers no other services except those described herein. It does not have any relationship or arrangement material to its advisory business or Clients with respect to the following entities: • broker-dealer, municipal securities dealer, or government securities dealer or broker, • an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund), futures commission merchant, commodity pool operator, or commodity trading advisor, lawyer or law firm, insurance company or agency, • other investment adviser or financial planner, • • banking or thrift institution, • accountant or accounting firm, • • • pension consultant, • • real estate broker or dealer sponsor or syndicator of limited partnerships. 16  BAKER STREET ADVISORS Independent. Customized. Focused. AMG As noted in Item 4: Advisory Business, "Principal Ownership," AMG holds an equity interest in the Adviser. AMG's equity interest in the Adviser is structured so that the Adviser maintains operational autonomy in managing its business. AMG does not have any role in the advisor's day-to-day management. AMG also holds equity interests in certain other Investment Managers, such as AMG Affiliates. In certain cases, the Adviser may select Investment Managers who are AMG affiliates to manage Client assets or may invest Client assets in funds managed by AMG affiliates. Each of the AMG Affiliates, including the Adviser, operates autonomously and independently of AMG and each other. The Adviser's selection of Investment Managers does not include any involvement or influence from AMG or any AMG Affiliate. As such, AMG's ownership interest in Baker Street does not, in our view, present any potential conflict of interest for our selection of Investment Managers or otherwise with respect to our Clients. More information regarding AMG, including its public filings and a list of all AMG Affiliates, is available at www.amg.com or upon request. Designations Certain employees can hold various designations related to their approved outside business activities, separate from their roles at Baker Street. The Adviser does not solicit Clients to engage in services associated with these designations or related outside business activities. Any recommendations or compensation received by Supervised Persons for services related to these designations are distinct from the advisory services and fees we provide. Clients are under no obligation to act upon any recommendations made by IARs in connection with these outside activities. Additionally, if Clients choose to follow such recommendations, they are not required to execute transactions through the IAR, nor are they obligated to use the Supervised Person’s services in their capacity as part of an outside business activity. Other Business Relationships Baker Street uses third-party resources to help run its business and provide services to its Clients, mostly back- office related. Baker Street sources these professionals acting in a Client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service Clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither the firm nor its employees receive compensation for such use or referrals. Baker Street acknowledges that certain financial activities, affiliations, relationships, and services may create conflicts of interest. The Adviser and employees may have financial incentives to recommend specific companies or services due to compensation received in connection with the transaction rather than based solely on the Client's needs. To address these conflicts, the Adviser requires all employees to always act in the best interests of each Client. Clients are under no obligation to act upon any recommendations or purchase additional products or services offered by us. If Clients choose to act on a recommendation, they are not required to execute transactions through Baker Street - they may choose to place their business and securities transactions with any brokerage firm or third party of their choice. Baker Street makes no assurances that products or services offered by other entities are available at the lowest possible cost. Clients may obtain the same products or services from different providers at lower prices. The decision to retain products or services remains solely with the Client. Outside of the relationships and affiliations disclosed herein, neither the Adviser nor its Management persons have any additional material relationships or conflicts of interest with other financial industry participants to disclose Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading __________________________________________________________________________________________ Code of Ethics Rule 204 A-1 under the Advisers Act requires all investment advisers registered with the SEC to adopt a Code of Ethics that sets forth standards of conduct and requires all of the Adviser’s employees to comply with the Federal securities laws. Baker Street takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of its employees. The firm strives to comply with all applicable laws and regulations governing its practices. It is committed to upholding the highest standards of trust, fair dealing, and integrity with each advisory Client. To that end, the Adviser has adopted a Code of Ethics (“Code”), which outlines the firm's conduct standards in alignment with its fiduciary obligations. Our Code requires all employees under the Advisers Act to exercise a fiduciary duty by acting in each Client's best interest and prioritizing the Client's interests above all else. The Code requires, among other things, employees: 17  BAKER STREET ADVISORS Independent. Customized. Focused. • act with integrity, competence, diligence, respect, and in an ethical manner with the public, Clients, prospective Clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets, • place the integrity of the investment profession, the interests of Clients, and the interests of the Adviser above one's interests, conduct all personal securities transactions in a manner consistent with this policy, • adhere to the fundamental standard that you should not take inappropriate advantage of your position, • avoid any actual or potential conflict of interest, • • use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities, • practice and encourage others to act professionally and ethically to reflect positively on yourself and the profession, • promote the integrity of and uphold the rules governing capital markets, • maintain and improve individual professional competence, strive to maintain and improve the • competence of other investment professionals, and comply with applicable provisions of the Federal securities laws. The Code applies to all Baker Street employees. Further, the Code specifies certain activities that may create actual or perceived conflicts of interest and sets forth reporting requirements and enforcement procedures. Employees are required to adhere to all relevant industry regulations and the firm’s written Policies & Procedures Manual, including any updates. Additionally, the Code includes comprehensive policies and procedures to prevent insider trading, ensuring that officers and employees of the Adviser do not misuse material non-public information. Employees are also bound by the AMG Insider Trading Policy and Procedures (the "AMG Insider Trading Policy"), which broadly prohibits the use of material and non-public information and imposes restrictions on the trading of AMG's stock. At the time of hire and periodically thereafter, Baker Street distributes its Code to all employees who must affirmatively commit to complying with state and federal securities laws, maintaining Client confidentiality, refraining from insider trading, complying with restrictions on accepting significant gifts, reporting outside activities, and adhering to personal securities trading procedures, among others, particularly for Access Persons. All employees are considered Access Persons. Employees are required to attest to their compliance and understanding of these provisions no less than annually. Baker Street also provides annual training on its Code and continuously monitors the activities of its employees to confirm alignment. A copy of the Adviser’s Code of Ethics is available for review, free of charge, to any Client or prospective Client upon request. Recommendations or Transactions in Securities with Material Financial Interests Neither the Adviser nor any IARs recommend to Clients or buy or sell for Client accounts securities in which the Adviser or an employee has a material financial interest. Participation or Interest in Investments in Securities Recommended to Clients The Adviser consults with an internal Investment Committee to guide model portfolios and asset allocation. In certain cases, we may recommend that Clients invest with Investment Managers whose employees serve on this advisory committee. While this relationship offers valuable insights, it also creates a potential conflict of interest, as the Adviser benefits from its consulting relationship with the Investment Managers. To address and mitigate conflicts of interest, Baker Street has established comprehensive procedures designed to manage conflicts arising from personal trading activities and relationships with Investment Managers. Specifically, employees may, on a limited basis, buy or sell securities for their accounts that are also recommended to Clients. This could create a conflict of interest if they materially benefit from such transactions. To manage this potential conflict, employees are required to pre-clear transactions in private placements and interests in private investment funds, subject to approval by the firm’s Chief Compliance Officer. Additionally, the personal investment activity of the Adviser’s employees is reviewed quarterly. They also must report certain personal securities transactions on a quarterly basis and provide an annual summary of holdings, including those 18  BAKER STREET ADVISORS Independent. Customized. Focused. in which they have a direct or indirect beneficial interest. This reporting requirement applies both upon commencement of employment and annually thereafter. Personal Trading & Pre-Clearance Procedures As noted above, Baker Street monitors all firm and employee personal trading activities to verify that such trades align with the fiduciary obligations owed to Clients. The Adviser’s policies and procedures regarding personal trading are designed to ensure that all trading activities are conducted in the best interest of Clients and in full compliance with applicable regulations. All personal securities transactions on the firm’s Restricted List require clearance from the Chief Compliance Officer or Designee and Baker Street retains the discretion to disapprove such personal securities transactions if they appear to create a conflict of interest or if the transaction otherwise seems improper. In addition, the Adviser has a strict prohibition against insider trading and has implemented policies and procedures to ensure compliance with this policy. Employees are well-versed in the rules regarding material non-public information and insider trading and are prohibited from using such information for personal gain. In all instances, the Client’s best interests remain paramount when executing trades. Employees are required to disclose their personal securities transactions at the time of onboarding and periodically thereafter and submit trade confirmations to the Chief Compliance Officer or Designee for review. The firm conducts regular reviews of personal trading activity, with a comprehensive review occurring no less than quarterly. In the event that a conflict of interest is identified, or a policy violation occurs, the firm will take appropriate corrective actions. Agency Cross-Trades An agency cross-trade occurs when an investment adviser executes a trade between two or more of its advisory Clients’ accounts. Baker Street does not engage in agency cross-trades. Principal Trades A principal trade is one in which an investment adviser, acting as principal for its account, buys securities from a Client or sells securities to a Client. Baker Street does not engage in principal trades. Trade Errors Even with the best efforts and controls, trade errors can happen. A "trade error" can include, among other things, the purchase or sale of an incorrect security, an incorrect amount of a security, or a failure to purchase or sell an intended security. Baker Street has internal controls in place to strive to prevent trade errors from occurring. We aim to detect trade errors prior to settlement and correct or mitigate them expeditiously. If a trade is placed for a Client's account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters, our policy is to restore the account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions can include canceling the trade, adjusting an allocation, and/or reimbursing the account. The goal of error correction is to make the Client whole. To the extent an error is caused by a counterparty, such as a broker, we will strive to recover any loss associated with such error from such counterparty. Generally, the Client will be reimbursed for any loss incurred due to a Baker Street trade error. In cases where trade errors result from the Client's inaccurate instructions, the trading error will remain the Client's financial responsibility. Baker Street maintains an accounting of each trade error within its books and records, including information about the trade and how such error was corrected. Item 12: Brokerage Practices __________________________________________________________________________________________ Preferred Custodians Following thorough due diligence and careful consideration of the brokerage practices outlined in this section, Baker Street will assist the Client in establishing a relationship with brokers with whom the Adviser has existing relationships to custody the Client's assets and facilitate trade executions, including Fidelity Brokerage Services LLC (“Fidelity”) and Charles Schwab & Co., Inc. (“Schwab”), each an unaffiliated, SEC-registered broker-dealer and member of FINRA / SIPC and SEI Investments Company. 19  BAKER STREET ADVISORS Independent. Customized. Focused. Factors Used to Select & Recommend Custodians & Broker-Dealers Baker Street will make recommendations based on the needs of the Client and the services provided by the broker/custodian, such as the ability to execute trades, margin rates, online access to accounts, transaction charges, consolidated reporting, duplicate monthly statements, access to mutual funds, including lower sales charges than for direct purchases and lower minimum purchase amounts, among others. Custodial Support Services Custodians provide independent investment advisory firms with access to institutional brokerage services, including trading, custody, reporting, and other related services. These services, typically unavailable to retail customers, are offered unsolicited, meaning advisory firms do not need to request them. This custodial support helps advisers like Baker Street manage Client accounts and grow their businesses. They are typically available at no charge, provided a qualifying amount of Client account assets is maintained with the custodian(s). As part of the programs offered by its custodians, Baker Street could receive benefits that it would not receive if it did not provide investment advice to Clients. These benefits do not depend on the amount of transactions directed by the Adviser to these custodians. Below is a description of some standard support services Baker Street can receive from its preferred custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and custody of Client assets. The investment products available include some that the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our Clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available that benefit investment advisers but do not directly benefit our Clients or their accounts. These products and services assist advisers with managing and administering Client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our Client accounts and software and other technology that:  provides access to Client account data (such as duplicate trade confirmations and account statements),  facilitates trade execution and allocates aggregated trade orders for multiple Client accounts,  includes pricing and other market data,  facilitate the payment of our fees from our Clients’ accounts, and  assists with back-office functions, recordkeeping, and Client reporting. Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: technology, compliance, legal, and business consulting,  educational conferences and events,   publications and conferences on practice management and business succession, and  access to employee benefits providers, human capital consultants, and insurance providers. Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. They can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Our custodians generally do not charge the firm’s Clients' custodial accounts separately for their services. Instead, the custodian is compensated by charging Clients commissions or other fees on the trades or settling into the custodial accounts. Custodians will charge Clients a percentage of the dollar amount of assets in the account for some custodial Client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to Client accounts are negotiated based on Baker Street’s commitment to maintaining Client assets in accounts at the custodian. This commitment benefits Clients because Clients' commission rates and asset-based fees are generally lower than if Baker Street had not committed to them. In addition to commissions or asset-based 20  BAKER STREET ADVISORS Independent. Customized. Focused. fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation Clients pay the executing broker- dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser may receive "soft dollar" benefits from custodians, which include research and other products and services in exchange for Client securities transactions or by maintaining account balances with the custodian. As noted previously, our preferred custodians offer a range of services, such as custody of Client securities, trade execution, clearance and settlement of transactions, platform system access, duplicate Client statements, research tools, access to the trading desk, block trading (aggregating securities transactions for execution and allocation), and other services. While custodial services are paid for as part of the Client’s fee, the additional services provided by custodians, which come at no direct cost to us, may influence our selection of custodians. Research services provided by broker-dealers may include information on economic and market conditions, individual securities, and industry developments. This research may be proprietary (produced by the broker’s staff) or third-party and can be delivered through written reports, calls, meetings with analysts or company management, and conference attendance. These services supplement our internal research and are subject to internal review before being incorporated into our investment process. Baker Street does not maintain formal soft dollar agreements with its custodians, each of whom could provide proprietary research. In general, Baker Street chooses to purchase external research. The receipt of research from custodians creates a conflict of interest, as it can incentivize the Adviser to recommend a custodian based on the research benefits received rather than the Client’s best interest in lower transaction costs or superior execution. The availability of these services is not contingent on specific future business commitments to any custodian, though pricing arrangements may vary based on the scope of business conducted. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation we might otherwise be able to negotiate; Clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), we may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction, recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker- dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our Clients and can be used in connection with Clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet our sourcing criteria for providing our Clients with a reliable and satisfactory custodial platform. Baker Street’s preferred custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause Clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services based on our interest in receiving the research or other products or services rather than on our Client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the Clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all Client accounts, not only those paid for the benefits. Given the Client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred Qualified Custodian selection is in the best interests of our Clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit us. 21  BAKER STREET ADVISORS Independent. Customized. Focused. Brokerage for Client Referrals Baker Street does not select or recommend a broker-dealer based on our interest in receiving Client referrals rather than solely prioritizing our Clients' interest in receiving the most favorable execution. Best Execution Baker Street acts on its duty to seek “best execution.” As a matter of policy and practice, the Adviser conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Baker Street seeks to ensure compliance with the Client's written Agreement and observe best practices. Still, a Client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While we will seek competitive rates, they may not necessarily obtain the lowest commission rates for Client transactions. Clients are encouraged to review the disclosure documents of any Investment Managers we recommend for managing their assets, as these documents provide important information regarding each manager’s policies on investment and brokerage discretion. As part of our services, the Investment Managers we recommend may execute trades through broker-dealers. We expect these managers to seek best overall execution based on the specific circumstances of each trade. Baker Street does not place orders or exercise trading authority over a Client’s account when a third-party Investment Manager has been granted such authority. Directed Brokerage Sometimes, a Client may direct Baker Street in writing to use another broker-dealer/custodian to execute some or all transactions for the Client’s account. In this situation, the Client will negotiate terms and arrangements for the account with the custodian. Baker Street will not seek better execution services, better prices, or aggregate Client transactions for execution through other custodians with orders for different accounts managed by us. As a result, the Client may not achieve the most favorable execution of Client transactions. Directed brokerage may cost the Client money. The Client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account that would otherwise be the case had the Client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Baker Street may decline a Client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Directed Brokerage Considerations for ERISA Clients In a retirement or ERISA plan, the Client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. In general, Baker Street does not advise on ERISA plans. Investment Allocation & Trade Aggregation Policy To the extent that Baker Street provides investment management services to its Clients, the transactions for each Client account generally will be independently placed unless we decide to purchase or sell the same securities for several Clients at approximately the same time. In such circumstances, the adviser may - but is not obligated to - combine such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among advisory Clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among Clients in proportion to the purchase and sale orders placed for each Client account on any given day. We shall not receive additional compensation or remuneration due to such aggregation. Accordingly, a Client may pay different prices for securities transactions than other Clients. Furthermore, we may be unable to buy and sell the exact quantities of securities for the Client, and they may pay higher commissions, fees, and/or transaction costs than other Clients. The aggregation has no value when trading non-ETF mutual funds, as each trade receives the same price. 22  BAKER STREET ADVISORS Independent. Customized. Focused. Trade Errors From time to time, Baker Street may make an error when submitting a trade order on a Client's behalf. When this occurs, Baker Street may place a correcting trade with the broker-dealer, who has custody of the Client's account. For the purpose of reconciling trade errors, Baker Street will keep a trade error account with each custodian. If the trade error results in a debit balance, this amount will be resolved immediately. At Schwab and SEI, if the trade error results in a credit balance, the amount can either be withdrawn or remain in the account; money market rates may be paid on credit balances. At Fidelity, effective March 1, 2016, if the trade error results in a credit balance, the amount will remain in the account for one month and can be netted against any debit balances. At the end of each month, any credit balance will be donated to charity. Item 13: Review of Accounts __________________________________________________________________________________________ Frequency & Nature of Account Reviews All Client accounts are reviewed at least quarterly to ensure that an appropriate allocation is in place based on Baker Street's assessments of market conditions and the circumstances of the Client. Baker Street will provide more frequent reviews as appropriate and as agreed with the Client. General conditions in the stock and bond markets are continuously monitored. Reviews may be conducted more frequently due to significant market, economic, or political events, Client requests, changes in investment objectives or guidelines, alterations in financial circumstances (such as retirement, job termination, relocation, or inheritance), material cash flows (whether expected or unexpected), changes in tax laws, new investment information, or shifts in the Client’s personal or financial situation. Additionally, macroeconomic factors and company-specific events may also prompt a review. Factors triggering buy or sell recommendations or changes in investment managers include changes in the Client’s circumstances, general market conditions (e.g., stock and bond markets), and changes in the management of investment managers. Reviews can also be conducted upon Client request. All accounts are reviewed by one of the firm's Advisors, and there is no set minimum or maximum number of accounts that each Advisor will review. Professional Services accounts are reviewed in accordance with the terms agreed upon with each Client. Client Account Reporting Clients are kept informed about their portfolio activity by receiving copies of transaction confirmations and monthly or quarterly statements from brokerage firms, mutual fund companies, or the custodian. Clients also receive quarterly reports prepared by the Adviser with their quarterly billing statements. These statements will be delivered by postal mail or electronically, as the Client selects. The quarterly reports provided by the Adviser may vary from statements provided by brokerage firms, mutual fund companies or custodial statements based on accounting procedures, reporting dates, and/or valuation methodologies of certain securities. Baker Street urges Clients to promptly review any statements they receive directly from their Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare account investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. Baker Street does not typically provide Clients with additional or more frequent written statements on their accounts, although ad hoc reports can be requested. Item 14: Client Referrals & Other Compensation __________________________________________________________________________________________ Baker Street receives an economic benefit from the following entities or individuals for providing investment advice or other advisory services: Preferred Qualified Custodian Benefits The Adviser may receive economic benefits from its recommended Qualified Custodians in the form of support products and services, which help offset costs Baker Street would otherwise bear directly. While Clients do not incur additional costs for assets held at a recommended custodian, they should be aware of potential conflicts of interest. The nature of the products and services provided by custodians and the associated benefits to us may influence 23  BAKER STREET ADVISORS Independent. Customized. Focused. the selection of a custodian. (For further details regarding these arrangements and any potential conflicts of interest, please refer to Item 12: Brokerage Practices.) Baker Street does not directly or indirectly compensate any person, other than employees, for Client referrals. Conflicts of Interest Apart from the items disclosed herein, Baker Street has no other additional economic benefits for Client referrals or compensation to disclose. Further details on how the Adviser mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. A free copy of our Code of Ethics is available for review to Clients and prospective Clients upon request by email. Item 15: Custody __________________________________________________________________________________________ Custodial Practices Baker Street does not have physical custody of client funds or securities, except for the standard business practice of deducting advisory fees directly from client accounts. The Adviser strictly prohibits the firm or its employees from obtaining, accepting, or maintaining custody of client funds, securities, or assets in any form. Clients' account cash, securities, and other assets will be held with a Qualified Custodian, who will govern the account under a separate written brokerage and custodial agreement between the custodian and the client. All account checks, funds, wire transfers, and securities will be delivered directly between the client and the custodian of record. The Adviser does not directly or indirectly hold client funds or securities and does not have the authority to take possession of, withdraw, or transfer any money, securities, or other property from any client custodial account. As noted previously, in most cases, we recommend that clients place their assets in the custody of Fidelity Brokerage Services LLC (“Fidelity”), Charles Schwab & Co., Inc. (“Schwab”), and SEI Investments Company who will take possession of the cash, securities, and other assets within the client's account unless the client directs otherwise. Typically, the custodian will directly debit the client's account(s) to pay our advisory fees. To authorize this, the client will directly provide written limited authorization instructions and request their custodian provide a "transfer of funds" notice through the client’s preferred method of communication after each advisory fee payment transfer occurs. The client will give these instructions separately on the custodian’s form. Although Baker Street does not have physical custody of client funds or securities, we are deemed to have limited custody over client funds, as defined by Rule 206(4)-2 under the Advisers Act, when a client authorizes us to deduct our advisory fee directly from their account. Wire Transfers, Check-Writing Authority & Standing Letters of Authorization Baker Street or persons associated with our firm can effect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, or we may have signatory and check-writing authority for client accounts if the client has provided us with written authorization to do so. Such written authorization is known as a "Standing Letter of Authorization" (or "SLOA"). An adviser who has authority to conduct third-party wire transfers, sign checks on behalf of a client, or serve as a trustee/management duties on client accounts has access to the client's assets and, therefore, is considered to have custody of those assets in any related accounts. Under the SEC's Custody Rule, advisers with custody are required to undergo surprise audits by an independent public accountant and meet other compliance requirements to safeguard client assets. Baker Street affirms it meets all regulatory requirements with respect to such accounts. Custodial Statements The Client’s selected custodian will send the client written account statements, at least quarterly, itemizing activity and account transactions, specific investments held in the account, the portfolio's value, deposits, withdrawals and advisory fees that occurred during the period of the statement. These statements will be delivered by postal mail or electronically, as the client selects. 24  BAKER STREET ADVISORS Independent. Customized. Focused. Baker Street urges Clients to promptly review any statements they receive directly from their Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare account investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. The Adviser cannot guarantee the accuracy or completeness of any report or other information provided to the Client by the custodian or another service provider. We encourage clients to question their assets' custody, safety, security, or any statements received and report inconsistencies. If a Client believes there are any inaccuracies or discrepancies in any reports received from their custodian, or if they do not understand the information in any report, document or statement received, they should promptly - and in all cases, before the next statement cycle, report any items of concern to their IAR or Baker Street directly. Unless the client indicates otherwise, by promptly notifying Baker Street in writing of concerns regarding statements received, investments Baker Street makes at their direction and in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. If Clients are not receiving statements, at least quarterly, from their Custodian, they should promptly inform their Custodian directly and their Advisor. Item 16: Investment Discretion __________________________________________________________________________________________ Account Management Style Baker Street’s advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Advisory Agreement reflects complete information for account management style. Discretionary Authority Under discretionary account management authority, Baker Street will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the Client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, Clients will provide discretionary management authority through written authorization, granting Baker Street complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as deemed appropriate by the Adviser, in accordance with the Client's investment risk profile and IPS (as applicable). This authority may be subject to modifications agreed upon by the Client and their IAR from time to time (collectively, the “Investment Guidelines”). (Note: Please note that this authority excludes certain money movement transactions. Baker Street will not initiate wire transfers or transfers of funds to third parties without the client's explicit written approval.) Discretionary authority is limited to investments within a Client's managed accounts. Clients will execute a Limited Power of Attorney, either as a standalone document or as part of the account opening documentation provided by their custodian. Baker Street is only required to obtain or maintain client consent for trades involving positions explicitly discussed during the introductory meeting (such as inherited stock the Client wishes to retain for sentimental reasons) or as otherwise specified. In all instances, discretionary authority will be exercised in alignment with the client’s stated investment objectives. This authority will remain in effect until the client terminates it through written notice to the Adviser, even in the event of the client’s incapacity or disability. Non-Discretionary Authority Where specifically requested by a Client, Baker Street will manage the Client’s account on a non-discretionary basis. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or other securities and refuse to approve securities transactions. Clients will execute all documents Baker Street, or their custodian requires to establish the account trading authorization. The Adviser will then recommend and direct the investment 25  BAKER STREET ADVISORS Independent. Customized. Focused. and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate to further the client’s investment guidelines, with such changes as the client and their IAR may agree to from time to time. Under this management style, Baker Street must receive approval from the Client before placing any trades in the Client's account. As a result, until the client’s IAR reaches the client, no transactions will be placed in the Client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the Client, until terminated in a written notice to the Adviser. For both account management styles, if Clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the Client repeatedly acts inconsistent with the jointly agreed upon investment objectives, Baker Street reserves the right to cancel the Client's Agreement after appropriate written notice. Similarly, the Client reserves the right to cancel their Agreement with Baker Street according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Baker Street will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and Client circumstances may require. Baker Street seeks to undertake minimal trading in Client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Item 17: Voting Client Securities __________________________________________________________________________________________ Proxy Voting Baker Street will not ask for or accept voting authority for Client securities. Clients will receive proxy material directly from the security issuer or custodian and are responsible for exercising their right to vote proxies. While Baker Street may assist a Client with their proxy questions, the Adviser shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in the above situations; it is the client's responsibility to vote their proxy. Clients should contact the security issuer before making their final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights of and remedies for large numbers of people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. The Client is responsible for class action suits, claims, bankruptcies or other legal actions and proceedings involving securities purchased or held in their account. Baker Street will not advise or act for the client in these types of legal proceedings involving securities held or previously held by the account or the issuers of these securities. Baker Street does not provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to Clients or their agents. Item 18: Financial Information __________________________________________________________________________________________ Balance Sheet Baker Street does not require nor solicit prepayment of more than $1,200 in fees per Client, six months or more in advance, and therefore, does not need to include a balance sheet with this Brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither the Adviser nor its management has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Baker Street has no additional financial circumstances to report. Bankruptcy Petitions in the Previous Ten Years Baker Street has not been the subject of a bankruptcy petition. 26 

Item 1: Cover Page __________________________________________________________________________________________ Form ADV Part 2B – Brochure Supplement (CRD #128066 / SEC #801-62370) 575 Market Street, Suite 600 San Francisco, CA 94105 T: 415.344.6180 www.BakerStreetAdvisors.com Updated: March 31, 2025 This brochure supplement provides information about Jeffrey M. Bardini, Jeffrey W. Colin, Adam T. Elegant, Alexander G. Gannon, Christopher H. Gordon, Jordan D. Kienzle, James E. Milligan, Ryan E. Murray, Heather L. Pelant, Annie E. Roth, Wendy A. Umphrey, and Christopher J. Wilkens. It supplements Baker Street Advisors' accompanying Form ADV brochure. Please contact us at 415.344.6184 if you have any questions about this brochure supplement or the Adviser's Form ADV brochure or if you would like to request additional or updated copies of either document. Nothing in this document is to be construed as a recommendation or an endorsement by the United States Securities and Exchange Commission ("SEC") or any state securities authority or an offer of securities; please refer to the actual investment offering and related legal documentation for complete disclosures. Registration as an investment adviser does not imply a certain level of skill or training. Investments involve risk, including the possible loss of principal. An adviser's written and oral communications provide you with information to determine whether to retain their services. This brochure is on file with the appropriate regulatory authorities as required by federal and state regulations. Additional information about the Adviser or any of its affiliated persons who are registered or required to be registered as Investment Advisor Representatives of the firm is available on the SEC's website at www.adviserinfo.sec.gov.  Table of Contents __________________________________________________________________________________________ Adam T. Elegant.................................................................................................................................... 5 Alexander G. Gannon............................................................................................................................ 6 Christopher H. Gordon........................................................................................................................... 7 Jordan D. Kienzle................................................................................................................................. 8 James E. Milligan................................................................................................................................... 9 Ryan E. Murray.....................................................................................................................................10 Heather L. Pelant..................................................................................................................................11 Annie E. Roth........................................................................................................................................12 Wendy A. Umphrey...............................................................................................................................13 Christopher J. Wilkens ...................................................................................................................... 14 Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 2  Jeffrey M. Bardini __________________________________________________________________________________________ Item 2: Educational Background & Business Experience Jeffrey M. Bardini was born in 1981. Mr. Bardini obtained a bachelor's degree in 2005 from California Polytechnic State University, San Luis Obispo, in 2005. Mr. Bardini has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Bardini has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 01/21 – Present Baker Street Advisors, LLC, San Francisco, CA Managing Director & Advisor Representative 04/16 – 12/20 Baker Street Advisors, LLC, San Francisco, CA Vice President & Advisor Representative Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Bardini providing advice to you. Mr. Bardini does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Bardini is a Managaing Director and Advisor Representative of Baker Street who dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Bardini does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Bardini complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 3  Jeffrey W. Colin __________________________________________________________________________________________ Item 2: Educational Background & Business Experience Jeffrey W. Colin was born in 1963. Mr. Colin obtained a bachelor's degree in Economics from Northwestern University in 1985, and an MBA from the J.L. Kellogg Graduate School of Management in 1991. Mr. Colin has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Colin has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 10/23 – Present Baker Street Advisors, LLC, San Francisco, CA Partner & Advisor Representative 12/02 – 08/03 Deutsche Bank Alex Brown, San Francisco, CA Managing Director 05/01 – 10/22 Robertson Stephens, San Francisco, CA Managing Director 02/00 – 05/01 myCFO, Inc., San Francisco, CA Managing Director 08/91 – 02/00 Goldman Sachs, Los Angeles & San Francisco, CA Vice President Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Colin providing advice to you. Mr. Colin does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Colin is a Partner and Advisor Representative of Baker Street who dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Colin does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Colin complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 4  Adam T. Elegant __________________________________________________________________________________________ Educational Background & Business Experience Adam T. Elegant was born in 1973. Mr. Elegant obtained a bachelor's degree in Political Science from Washington University in St. Louis in 1995, and an MBA from the Leeds School of Business at the University of Colorado in 1999. Mr. Elegant has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Elegant has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 01/22 – Present Baker Street Advisors, LLC, San Francisco, CA Partner & Advisor Representative 11/19 – 12/21 Baker Street Advisors, LLC Managing Director & Investment Advisor Representative 04/14 – 11/19 KKR & Co., Inc., San Francisco, CA Director 04/13 – 03/14 Northern Trust, San Francisco, CA Vice President 08/99 – 04/13 Goldman Sachs, San Francisco, CA Vice President Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Elegant providing advice to you. Mr. Elegant does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Elegant is a Partner and Advisor Representative of Baker Street who dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Elegant does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Elegant complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 5  Alexander G. Gannon __________________________________________________________________________________________ Educational Background & Business Experience Alexander G. Gannon was born in 1989. Mr. Gannon obtained a Bachelor of Business Administration degree from the University of Notre Dame in 2011. Mr. Gannon has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Gannon has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 04/23 – Present Baker Street Advisors, LLC, San Francisco, CA Managing Director & Advisor Representative 01/20 – 04/23 Baker Street Advisors, LLC, San Francisco, CA Vice President & Advisor Representative 07/16 – 12/19 Baker Street Advisors, LLC, San Francisco, CA Manager & Advisor Representative Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Gannon providing advice to you. Mr. Gannon does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Gannon is a Managing Director and Advisor Representative of Baker Street, and he dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Gannon does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Gannon complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 6  Christopher H. Gordon __________________________________________________________________________________________ Educational Background & Business Experience Christopher H. Gordon was born in 1988. Mr. Gordon obtained a bachelor of Science in Business Administration degree from Boston University in 2011 and earned an MBA in 2021 from the Haas School of Business, University of California, Berkeley. Mr. Gordon has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Gordon has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 03/25 – Present Baker Street Advisors, LLC, San Francisco, CA Managing Director & Advisor Representative 12/20 – 03/25 Baker Street Advisors, LLC, San Francisco, CA Vice President & Advisor Representative Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Gordon providing advice to you. Mr. Gordon does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Gordon is a Managing Director and Advisor Representative of Baker Street, and he dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Gordon does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Gordon complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 7  Jordan D. Kienzle __________________________________________________________________________________________ Educational Background & Business Experience Jordan D. Kienzle was born in 1984. Mr. Kienzle obtained a bachelor of Science in Business Administratiodegree from Elon University in 2006 and an MBA from the University of Chicago Booth School of Business in 2013. Mr. Kienzle has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Kienzle has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 12/21 – Present Baker Street Advisors, LLC, San Francisco, CA Partner & Advisor Representative 03/18 – 12/21 Baker Street Advisors, LLC, San Francisco, CA Senior Vice President & Advisor Representative Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Kienzle providing advice to you. Mr. Kienzle does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Kienzle is a Partner and Advisor Representative of Baker Street, and he dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Kienzle does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Kienzle complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 8  James E. Milligan __________________________________________________________________________________________ Educational Background & Business Experience James E. Milligan was born in 1961. Mr. Milligan obtained a Bachelor of Science degree in Civil Engineering from the University of Texas at Austin in 1983, and a Master of Business Administration from the Stanford Graduate School of Business in 1987. Mr. Milligan has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Milligan has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 01/16 – Present Baker Street Advisors, LLC, San Francisco, CA Partner & Advisor Representative 03/11 – 12/15 Baker Street Advisors, LLC, San Francisco, CA Managing Director & Advisor Representative 02/99 – 03/08 Goldman Sachs, San Francisco, CA Managing Director & Regional Manager Private Wealth Management (PWM) 04/97 – 01/99 Goldman Sachs, Houston, TX Managing Director & Regional Manager (PWM) 08/87 – 04/97 Goldman Sachs, Houston, TX Vice President and Private Client Advisor (PWM) Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Milligan providing advice to you. Mr. Milligan does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Milligan is a Partner and Advisor Representative of Baker Street, and he dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Milligan does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Milligan complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 9  Ryan E. Murray __________________________________________________________________________________________ Educational Background & Business Experience Ryan E. Murray was born in 1985. Mr. Murray obtained a Bachelor of Arts degree from the University of Richmond in 2007. Mr. Murray has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Murray has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 04/23 – Present Baker Street Advisors, LLC, San Francisco, CA Managing Director & Advisor Representative 09/22 – 04/23 Syon Capital, LLC, San Francisco, CA Chief Relationship Officer 09/19 – 09/22 Merrill Lynch & Co., San Francisco, CA Vice President 07/07 – 09/19 Goldman Sachs & Co., San Francisco, CA Vice President Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Murray providing advice to you. Mr. Murray does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Murray is a Managing Director and Advisor Representative of Baker Street, and he dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Murray does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Murray complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 10  Heather L. Pelant __________________________________________________________________________________________ Educational Background & Business Experience Heather L. Pelant was born in 1968. Ms. Pelant obtained a Bachelor of Arts from the University of Victoria in 1991, a Master of Arts from the University of Hawaii in 1996, and a Master of Business Administration from the J.L. Kellogg Graduate School of Management in 2009. Ms. Pelant has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to her academic qualifications, Ms. Pelant has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 01/20 – Present Baker Street Advisors, LLC, San Francisco, CA Partner & Advisor Representative 12/16 – 12/19 Baker Street Advisors, LLC, San Francisco, CA Managing Director 01/03 – 08/16 BlackRock, San Francisco, CA, Hong Kong, Toronto Managing Director 01/97 – 01/02 Morgan Stanley, San Francisco, CA & Honolulu, HI Vice President Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Ms. Pelant providing advice to you. Ms. Pelant does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Ms. Pelant is a Partner and Advisor Representative of Baker Street, and she dedicates her full attention to this role during trading hours. She is not involved in any other investment-related activities or volunteer work, nor does she receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Ms. Pelant does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Ms. Pelant complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 11  Annie E. Roth __________________________________________________________________________________________ Educational Background & Business Experience Annie E. Roth was born in 1980. Ms. Roth obtained a Bachelor of Arts in Physics from the University of California, Berkeley, in 2004. Ms. Pelant has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to her academic qualifications, Ms. Pelant has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 04/23 – Present Baker Street Advisors, LLC, San Francisco, CA Managing Director & Advisor Representative 01/22 – 04/23 Baker Street Advisors, LLC, San Francisco, CA Senior Vice President & Advisor Representative 07/17 – 01/22 Baker Street Advisors, LLC, San Francisco, Vice President 04/13 – 07/17 Baker Street Advisors, LLC, San Francisco, CA Manager 04/11 – 04/13 Wetherby Asset Management, San Francisco, CA Investment Associate 05/04 – 04/11 UBS, San Francisco, CA Registered Client Service Associate, Technical Analyst & Investment Associate Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Ms. Roth providing advice to you. Ms. Roth does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Ms. Roth is a Managing Director and Advisor Representative of Baker Street, and she dedicates her full attention to this role during trading hours. She is not involved in any other investment-related activities or volunteer work, nor does she receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Ms. Roth does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Ms. Roth complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 12  Wendy A. Umphrey __________________________________________________________________________________________ Wendy A. Umphrey was born in 1971. Ms. Umphrey obtained a Bachelor of Arts from the University of Michigan in 1993. Ms. Umphrey has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to her academic qualifications, Ms. Umphrey has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 01/20 – Present Baker Street Advisors, LLC, San Francisco, CA Partner & Advisor Representative 01/17 – 12/19 Baker Street Advisors, LLC, San Francisco, CA Managing Director 04/07 – 12/16 Baker Street Advisors, LLC, San Francisco, CA Vice President Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Ms. Umphrey providing advice to you. Ms. Umphrey does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Ms. Umphrey is a Partner and Advisor Representative of Baker Street, and she dedicates her full attention to this role during trading hours. She is not involved in any other investment-related activities or volunteer work, nor does she receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Ms. Umphrey does not receive any additional economic benefits from any person, company, organization, or entity— other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Ms. Umphrey complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 13  Christopher J. Wilkens __________________________________________________________________________________________ Christopher J. Wilkens was born in 1971. Mr. Wilkens obtained Bachelor of Arts from the University of Wisconsin–Madison in 1993. Mr. Wilkens has met Baker Street Advisors' requirement that its investment professionals ("Advisor Representatives" or "IARs") possess either a bachelor's degree or equivalent, advanced coursework (such as an MBA, DFP, CFA, CFP®, ChFC®, JD, CTFA, EA, or CPA®), or relevant work experience demonstrating strong knowledge and aptitude in investment management principles. In addition to his academic qualifications, Mr. Wilkens has demonstrated a comprehensive understanding of economic and financial concepts, modern portfolio theory, and portfolio optimization techniques developed through a combination of formal education, industry experience, securities examinations, and/or the attainment of recognized professional designations. 03/07 – Present Baker Street Advisors, LLC, San Francisco, CA Partner 04/03 – 02/07 VERITY Wealth Advisors, LLC, San Francisco, CA Principal 04/97 – 04/03 Merrill Lynch & Co., San Francisco, CA Director 04/96 – 04/97 Barclays de Zoete Wedd Securities, Ltd., San Francisco, CA Associate 07/93 – 04/96 Goldman Sachs, New York, NY Analyst Item 3: Disciplinary Information Baker Street Advisors ("Baker Street") is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Mr. Wilkens providing advice to you. Mr. Wilkens does not have a disciplinary history, which may be material to a client's or prospective client's evaluation of him or this advisory business. You may evaluate the details of this history on the SEC's IAPD website at www.adviserinfo.sec.gov. Item 4: Other Business Activities Mr. Wilkens is a Partner and Advisor Representative of Baker Street, and he dedicates his full attention to this role during trading hours. He is not involved in any other investment-related activities or volunteer work, nor does he receive compensation for any business endeavors outside of his position with the Adviser. Item 5: Additional Compensation Mr. Wilkens does not receive any additional economic benefits from any person, company, organization, or entity—other than the Adviser in connection with the provision of advisory services to clients. Item 6: Supervision Baker Street is committed to maintaining the highest standards of regulatory compliance and business ethics. The firm's Chief Compliance Officer ("CCO"), Jennifer L. Bonvechio (T: 415.344.6184), is responsible for developing, implementing, and overseeing the firm's Compliance Program. Investment recommendations are collaboratively agreed upon and overseen by the Baker Street Investment Committee, which is comprised of all of the Baker Street Partners and Managing Directors, as well as the CCO. Shelby Rogers (T: 415.344.6180) directly supervises all employee trading activities, which are monitored through ongoing in-office interactions and the firm's client relationship management system. Baker Street's policy is to operate in strict compliance with all applicable federal and state regulations and adhere to the highest principles of ethical conduct. Adviser Representatives are required to follow the firm's written supervisory procedures and Code of Ethics ("COE" or "the Code"), including all updates. The Code mandates that employees uphold their fiduciary duty by acting in the best interest of clients and placing client interests above all else. All employees must avoid any activities that conflict, or appear to conflict, with these principles or the firm's interests. At least annually, employees are required to attest to their understanding of and compliance with the firm's policies and expectations. This includes an explicit acknowledgment by each IAR of their responsibilities and duties as outlined in the Code. Mr. Wilkens complies fully with all applicable regulations governing the conduct of Baker Street employees. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 14