EAGLE GLOBAL ADVISORS LLC

Eagle Global Advisors, LLC Part 2A of Form ADV The Brochure 1330 Post Oak Blvd., Suite 3000 Houston, TX 77056 (713) 952-3550 www.eagleglobal.com Updated: March 26, 2025 This brochure provides information about the qualifications and business practices of Eagle Global Advisors, LLC (“Eagle Global” or the “Company”). If you have any questions about the contents of this brochure, please contact us at 713-952-3550. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC does not imply any level of skill or training. Additional information about the Company is also available on the SEC’s website at: www.adviserinfo.sec.gov. 1  Material Changes There have been no material changes to note since our last annual amendment on March 13, 2024. We encourage you to read this brochure carefully in its entirety as we have made certain non-material revisions for additional clarity. Table of Contents Material Changes ............................................................................................................................................. 2 Table of Contents ............................................................................................................................................. 2 Advisory Business ........................................................................................................................................... 2 Fees and Compensation ................................................................................................................................... 4 Performance Based Fees and Side-by-Side Management ................................................................................ 6 Types of Clients ............................................................................................................................................... 7 Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 7 Disciplinary Information ................................................................................................................................ 13 Other Financial Industry Activities and Affiliations ....................................................................................... 13 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................... 14 Brokerage Practices ....................................................................................................................................... 15 Review of Accounts ....................................................................................................................................... 17 Client Referrals and Other Compensation ..................................................................................................... 17 Custody ......................................................................................................................................................... 18 Investment Discretion .................................................................................................................................... 18 Voting Client Securities ................................................................................................................................. 18 Financial Information .................................................................................................................................... 19 Advisory Business Eagle Global was founded in November 1996 and is principally owned by Edward Allen and Steven Russo. As of December 31, 2023, the Company managed $2,461,774,037 on a discretionary basis. Eagle Global also provides investment research and model investment recommendations to accounts of third-party advisors with a value of $122,553,816. The Company employs a variety of investment strategies to develop an individually managed account customized to each client’s time horizon, lifestyle and investment objectives, and has the flexibility to accommodate portfolio requirements and restrictions in such accounts. The Company has also customized strategies for investments in its private fund and mutual fund vehicles. Eagle Global’s investment strategies are described in greater detail under the section titled Methods of Analysis, Investment Strategies, and Risk of Loss of this Brochure. Advisory Services The Company’s investment advisory services begin on the date that the account is accepted by Eagle Global and initially allocated into the management positions. There are certain instances where a client agreement will be received but be pending for a period of time due to account restrictions, anticipation of an upcoming strategy change or other operational issues. The Company is not responsible for performance prior to the acceptance and establishment of investment advisory services by the Company. Clients and/or their solicitor’s agent, consultant, or adviser may contact the Company at any time to inquire on the status of their account. The Company’s asset management services to its clients generally include the following: 2  Investor Profile — The Company consults with the client or client’s consultant to obtain their investment objectives profile. The Company works with the client or client’s consultant to determine the appropriate investment guidelines, risk tolerance and other factors that will assist in ascertaining the suitability of managing the account. Portfolio Management Selection — The Company diversifies and manages the client’s portfolio. Investments are determined based upon the client’s investment objectives, risk tolerance, net worth, net income and other various suitability factors. The Company manages the client’s accounts on an individualized basis. Restrictions and guidelines are accepted by Eagle Global, and when imposed may affect the composition and performance of a client’s portfolio compared to other clients. Performance Evaluation and Monitoring Services — The Company will furnish performance measurement services to its clients or clients’ consultants, provided by the custodian broker/dealer and through internally generated reports, in the form of quarterly performance evaluation reports. The internal reports are intended to inform clients or the clients’ consultants as to how their investments have performed for the selected period. Wrap Fee Relationships Eagle Global serves as a portfolio manager for a variety of wrap fee programs. The advisory services provided to clients participating in a wrap fee program (“Wrap Program Clients”) are substantially similar to those discussed above. These wrap fee programs are arrangements in which investment advisory services, brokerage execution services and custody are provided by a sponsor for a single predetermined "wrap" fee (regardless of the number of trades completed by a client). Generally, Wrap Program Clients pay this single, all-inclusive fee quarterly in advance to the program sponsor, based on the net assets under management. The Company receives from the program sponsor a portion of the wrap fee for the portfolio management services it provides. Each program sponsor has prepared a wrap brochure which contains detailed information about its wrap fee program, including the wrap fee charged. Copies of each wrap brochure are available from the program sponsor upon request. Each wrap program sponsor has retained the Company through a separate investment advisory contract. Wrap Program Clients should note that the Company will execute transactions for their accounts through the wrap sponsor. Transactions executed through a wrap sponsor may be less favorable in some cases than the Company’s clients whose trades are not executed through the wrap sponsor. This is because the Company has no ability to negotiate price or take advantage of combined orders or volume discounts when executing transactions through the wrap sponsor. Please contact Steven Russo for a full listing of Wrap Fee Programs for which Eagle Global serves as a portfolio manager. Research and Model Investment Recommendation Services (“Research Services”) The Company provides research and model portfolio investment recommendations to several clients. The Company provides these clients solely with research services and does not provide trading or additional services. These clients use research provided by Eagle Global to implement investment recommendations for their own clients. Sub and Co-Advisory Relationships Eagle Global serves as an investment co-advisor to the Eagle MLP Strategy Fund and subadvisor to the Timothy Plan Israel Common Values Fund and the Timothy Plan International Fund. Eagle Global also serves as subadvisor to TrueShares Eagle Global Renewable Energy Income ETF. Private Funds Eagle Global acts as investment adviser to the following private funds (collectively, “Private Funds”): 3  • Eagle Income Appreciation Partners, L.P. and Eagle Income Appreciation II, L.P. (the “Energy Infrastructure Partnerships”). The Energy Infrastructure Partnerships are Texas limited partnerships which were formed to invest in master limited partnerships (MLPs) and other securities which are believed to have a high likelihood of producing an attractive rate of return from both capital appreciation and income. Eagle Income Appreciation GP, LLC, a Delaware limited liability company, is general partner of the Energy Infrastructure Partnerships. • Eagle Scarcity Partners, LP is a Texas limited partnership formed to invest in securities that should appreciate from the scarcity of specific commodities, precious metals, and digital assets. Eagle Scarcity Partners, GP, LLC, a Texas limited liability company, is general partner of Eagle Scarcity Partners. LP. For new private fund investors, subscription wires received prior to the effective investment dates of their respective capital accounts will be held in escrow until such investment date. Fees and Compensation Generally Fees are payable in arrears by separate account clients on the last day of each quarter. However, such fees may be paid quarterly in advance depending on the Company arrangement with the client. Advisory fees are generally directly debited from the client’s custodial account; however, certain clients are invoiced directly for our advisory fees. Clients are afforded the option to select the method of payment they prefer. Either party may terminate the contract at any time with written notice. Fees are prorated to the amount of days in the quarter in which the client received the Company’s services. All fees and fee structures are negotiable, including whether fees will or will not be charged on any cash held in a client’s portfolio and whether multiple accounts may be aggregated for fee reduction purposes. Fees will be in compliance with Rule 205-3 under the Investment Advisers Act of 1940 (“Advisers Act”). Management fees charged are separate and distinct from the fees and expenses charged by mutual funds, ETFs, ETNs and closed-end funds which may be recommended to clients. A description of these and other expenses are available in each mutual fund’s prospectus. However, clients that have invested in the mutual funds advised by Eagle Global will not be charged advisory fees on the portion of the account that is invested in an Eagle Global advised mutual fund. Clients may incur other additional charges imposed by third parties other than the Company. For example, clients other than Wrap Program Clients are responsible for trading costs and custodial fees. Please refer to the Brokerage Practices section of this brochure for details on the Company’s brokerage arrangements. Separately Managed Accounts Domestic Securities 1% on first $2,000,000 and .6% thereafter Minimum fee $10,000 International Equities 1% .90% .85% .80% .70% $0 to $5 million $5 to $10 million $10 to $25 million $25 to $50 million $50 to $100 million $100 million and over negotiable Minimum fee $10,000 Energy Infrastructure 0.95% of assets for Quality Core Strategy 4  No minimum fee 1.25% of assets for Total Return Strategy Minimum fee of $10,000 Renewables Infrastructure 0.75% of assets Minimum fee $2,500 BDC 0.75% of assets Minimum fee $2,500 Wrap Fee Programs Wrap Program Client fees and termination policies are agreed upon as stated in the agreement between the wrap fee sponsor and Eagle Global and disclosed in the sponsor’s Appendix 1/Wrap Brochure to Form ADV Part 2A. Research Services The Company’s fees for Research and Model Investment Recommendation Services are negotiated on a case- by-case basis. Sub and Co-Advisory Relationships The fee schedule and termination policies for sub and co-advisory services are negotiated separately by the Company and the investment or trust companies that Eagle Global advises. The fees paid to the Company generally range from .30 % to 1.0 % of assets under management, depending on the strategies employed, the level of assets to be managed and the amount of client servicing required. Private Funds Energy Infrastructure Partnerships The Company receives a management fee from the Energy Infrastructure Partnerships equal to 1% per annum of the value of the investor’s pre-distribution capital account balance, payable quarterly in arrears. Eagle Income Appreciation GP, LLC receives additional performance-based fees discussed below. Eagle Scarcity Partners, L.P. The Company receives a management fee from Eagle Scarcity Partners, LP equal to 1% per annum of the value of the investor’s pre-distribution capital account balance, payable quarterly in arrears. Eagle Scarcity Partners, GP, LLC receives additional performance-based fees discussed below. Other Fees and Expenses of the Private Funds Generally, each Private Fund (and indirectly its investors) may also bear all costs and expenses arising in connection with its operation, including: (i) all costs and expenses directly related to a Private Fund’s investments or prospective investments, including transactions costs, custody fees, fees of professional advisors and consultants, due diligence expenses (ii) fees, expenses, interest payments, and principal payments due to any financing sources, (iii) any withholding or transfer taxes imposed on the Private Fund (or any partner); (iv) any governmental, regulatory, licensing, filing or registration fees, (v) any interest due to the partners in connection with capital withdrawals; (vi) any legal, auditing, consulting, research, advisory, accounting, and administrative fees and expenses. The expenses described herein are qualified in their entirety by the actual fees and expenses described in each Private Fund’s Private Placement 5  Memorandum. Performance Based Fees and Side-by-Side Management As compensation for its services to the Energy Infrastructure Partnerships, Eagle Income Appreciation GP, LLC (an Eagle Global affiliate) is entitled to a performance-based profit allocation with respect to each investor in Eagle Income Appreciation Partners, LP and Eagle Income Appreciation II, LP equal to 10% multiplied by the amount (if any) by which the pre-distribution capital account balance of such investor as of the end of each allocation period exceeds the sum of a high water mark amount plus a hurdle return of 8% per annum on the high water mark amount for the allocation period where the high water mark amount is the highest value of such investor’s pre-distribution capital account balance as of the end of any prior fiscal year end (or at inception if the investor was admitted to the partnership during the current fiscal year) appropriately adjusted for intervening capital contributions, withdrawals and distributions to make such balances comparable. As compensation for its services to Eagle Scarcity Partners, L.P., Eagle Scarcity Partners GP, LLC (an Eagle Global affiliate) is entitled to a performance-based profit allocation with respect to each investor in Eagle Scarcity Partners, LP equal to 20% multiplied by the amount (if any) by which the pre-distribution capital account balance of such investor as of the end of each allocation period exceeds the sum of a high water mark amount plus a hurdle return of 10% per annum on the high water mark amount for the allocation period where the high water mark amount is the highest value of such investor’s pre-distribution capital account balance as of the end of any prior fiscal year end (or at inception if the investor was admitted to the partnership during the current fiscal year) appropriately adjusted for intervening capital contributions, withdrawals and distributions to make such balances comparable. In addition, the Company shares an ownership interest in the General Partner of a fund which it no longer manages. Specifically, the Company owns a portion of the EMC Asset Management, LLC, which is the General Partner to the EMC Alpha Fund. This General Partner can receive an incentive allocation of ten percent (10%) of any investor’s share of any net profits, including realized and unrealized gains and losses, for such fiscal year, subject to a loss carryforward provision or “high water mark”. Only accredited investors are permitted to invest in the Private Funds. Additionally, only qualified clients within the meaning of Rule 205-3 under the Advisers Act can be investors in Eagle Income Appreciation Partners LP. Only qualified clients and qualified purchasers within the meaning of Section 2(a)(51) of the Investment Company Act of 1940 can be investors in Eagle Income Appreciation II, L.P and Eagle Scarcity Partners, LP. The fact that the Company is compensated based on the trading profits creates an incentive for the Company to make investments on behalf of clients that are riskier or more speculative than would be the case in the absence of such compensation. In addition, a portion of the performance-based fee received by the Company is based on realized and unrealized gains and losses. As a result, the performance-based fee earned could be based on unrealized gains that clients may never realize. Providing advisory services to Eagle Income Appreciation Partners, LP and Eagle Income Appreciation II, LP, which pay performance-based fees, and similar accounts that pay asset based fees creates a conflict of interest. Eagle Global may have an incentive to favor accounts for which we receive a performance-based fee. To mitigate this conflict, the Company has implemented policies and procedures, including those discussed below regarding the aggregation and allocation of trades. 6  Types of Clients Eagle Global generally provides investment advice to high net worth individuals, retirement plans for corporations and unions, financial institutions, trusts, endowments, foundations, and registered and unregistered investment companies. In general, the minimum account size for a separately managed account is $1,000,000, unless an exception is agreed by the members of the Company. The minimum account value for the Quality Core MLP and Renewables Income is $250,000 and the minimum account size for the Total Return MLP strategy is $5,000,000. The minimum investment for each of the Private Funds is discussed in the relevant Private Funds’ Private Placement Memorandum. Methods of Analysis, Investment Strategies and Risk of Loss Strategy Descriptions Eagle Global generally manages client accounts according to one or several of the following strategies, that are intended to identify companies with improving growth potential unrecognized by current valuations: • Domestic Equity Strategy – This portfolio seeks to combine both growth and value factors through investments in large-cap U.S. equities; • International Equity Strategy – This portfolio seeks to combine both growth and value factors through investments in large-cap international equities; • Global Equity Strategy – This portfolio seeks to combine both growth and value factors through investments in large-cap U.S. equities and large-cap international equities; • Fixed Income Strategy – This portfolio seeks preservation and low risk total returns through investments in investment grade bonds of intermediate maturities (less than 10 years), as well as ETFs, ETNs and Mutual Funds. Fixed income accounts are intended to provide capital preservation and low risk; • Energy Infrastructure Strategy – These portfolios seek tax advantaged income generation, capital appreciation, and lower volatility through investments in master limited partnerships and MLP related corporations. The Company offers Total Return and Quality Core MLP strategies under the Energy Infrastructure umbrella; o The Total Return MLP strategy seeks a high total rate of return from both tax advantaged income and capital appreciation through investments in master limited partnerships and other midstream companies. o The Quality Core MLP strategy is designed for greater concentration of holdings and lower turnover. • Renewables Infrastructure Strategy – This portfolio seeks to access the core value proposition of the renewable infrastructure asset class through a concentrated portfolio of renewable infrastructure companies. The strategy targets a combination of dividends and long-term stock appreciation; • Business Development Company (BDC) Strategy - Business Development Companies are specialized securities that most commonly invest in the debt of middle-market private companies in the United States. These securities are organized as closed-end funds and as such can trade in the 7  stock market at a premium or discount to the value of their underlying assets. These securities also typically offer relatively high distribution yields versus other public securities. This strategy seeks to provide a superior total return with a significant component from current income by active investment in a concentrated portfolio of Business Development Companies; • Eagle Scarcity Partners, LP Strategy – This strategy seeks total return through investment securities that should appreciate from the scarcity of specific commodities, precious metals, and digital assets. Within each separately managed account strategy, client accounts are generally managed to a model and are subject to client imposed investment restrictions and valuations of the securities. Within each Private Fund strategy, investor capital is managed based on the strategy described in the Private Placement Memorandum (PPM). Investment Processes Eagle Global’s investment process for Domestic, Global, and International Equities incorporates both top- down and bottom-up elements and is designed to identify companies with improving growth prospects that have not been incorporated into current valuations. The Company utilizes a Smart IQ proprietary screening methodology to determine the universe of potential investments and employs a series of quantitative multi- factor models that are used to provide both top-down and bottom up analysis. The models provide directional guidance towards countries, sectors and stocks with improving prospects. Additionally, company-specific ideas are subjected to traditional fundamental analysis including a qualitative analysis of a company’s competitive strengths, weaknesses and industry positioning as well as the company’s management strength and integrity. Eagle Global also performs an analysis of company financials. The Company utilizes various sources of information such as FactSet, CSFB HOLT, and Bloomberg databases in conducting its analysis. Eagle Global’s Fixed Income strategy investments are determined through traditional top down and bottom-up fundamental analysis in an effort to construct a portfolio with the desired maturity and quality characteristics. The strategy makes investments in taxable and tax-free bonds, ETFs, ETNs and mutual funds that are primarily composed of intermediate maturity and investment grade securities. The strategy investments are adjusted to changing economic and interest rate conditions. The strategy investments seek to achieve capital preservation, income generation and low risk total return. Investment decisions for this strategy are made by the Fixed Income Investment Committee. Eagle Global’s Energy Infrastructure Strategy investments are determined through traditional fundamental analysis. Financial models, analyst research and meetings with company management are used to select attractive MLPs and MLP related corporations. The Energy Infrastructure Strategy focuses on investing in units of master limited partnerships, corporations that own and invest in MLP and midstream related assets, based on each unit’s anticipated total return potential and risk characteristics. Investment decisions are made at the discretion of the Energy Infrastructure portfolio manager upon recommendations made by the Energy Infrastructure investment team. Eagle Global’s Renewables Infrastructure Strategy investments are determined through traditional fundamental analysis. Financial models, analyst research and meetings with company management are used to select attractive renewable infrastructure companies. The Renewables Infrastructure Strategy focuses on companies that own and invest in renewable infrastructure assets, based on each company’s anticipated total return potential and risk characteristics. Investment decisions are made at the discretion of the Renewables Infrastructure portfolio managers upon recommendations made by the Renewables Infrastructure investment team. Eagle Global’s Business Development Company (BDC) Strategy investments are determined by traditional fundamental analysis. Eagle Global has developed a number of quantitative screens on various financial metrics that have historically been associated with superior returns on BDC securities. Such factors include, 8  but are not limited to, the Price-to-Book, Return-on-Equity, Price-to-Earnings, and Book-Value-per-share growth. These screens in general seek to identify securities that are selling at a good value but that have proven to earn a superior return on their capital. Eagle Global also makes a number of qualitative determinations regarding the strength of the management of each BDC, their ability to source and evaluate good investments, as well as manage to minimize risks. Eagle Global conducts its qualitative assessments through interactions with company managements and independent assessments by market participants. Eagle Global’s Scarcity Strategy investments are determined by traditional top-down and bottom-up analysis to identify securities with favorable exposure to anticipated scarcity. Eagle evaluates the securities with a focus on the sensitivity to the anticipated scarcity, the physical location of any mines or other fixed assets, and the strength of the management team. Risks Involved General Investment Risks All investing involves a risk of loss that clients should be prepared to bear. There is no guarantee that any strategy’s investment objective will be met, and the investment strategies offered by Eagle Global could lose money over short or even long periods. In adverse market conditions the Company may use cash as a method for protecting client portfolios. Performance could be hurt by any number of different market risks including but not limited to: Equity Securities The value of equity securities fluctuates in response to issuer, political, market, and economic developments. Fluctuations can be dramatic over the short-term as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. For example, large cap stocks can react differently from small cap stocks, and "growth" stocks can react differently from "value" stocks. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo-political risks have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term effects on world economies and markets generally. In addition, the value of portfolios may fluctuate as the general level of interest rates fluctuates. Mutual & Exchange Traded Funds Mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments following the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage - borrows money to a significant degree, or concentrates in a particular type of security rather than balancing the fund with different security types. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Further, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. 9  Small and Micro Capitalization Companies Eagle Global may invest a portion of its assets in small, micro, and/or unseasoned companies with small market capitalizations. While smaller companies generally have greater potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. Non-U.S. Securities Eagle Global invests in non-U.S. securities for many clients. International securities will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and non- U.S. issuers and markets are subject. These risks include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels and limitations on the use or transfer of assets. Some international investments are made in emerging markets. Investments in emerging markets may be impacted by economic conditions in which those companies operate. Many developing countries have a history of economic instability and Eagle Global’s success may depend on the overall level of economic activity and political stability in these emerging markets. Short Selling Short selling transactions expose clients to the risk of loss in an amount greater than the initial investment, and such losses can increase rapidly and without effective limit. There is the risk that the securities borrowed by a client in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur, wherein an adviser, on behalf of a client account, might be compelled at the most disadvantageous time to replace the borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. Fixed Income Securities Risks associated with investing in fixed income securities include: Illiquidity in the bond market may make the bond difficult or impossible to sell; • The bond issuer’s inability to pay interest or repay the bond; • Changes in market interest rates cause the bond’s value to fall; • • The bond issuer may repay the bond prior to maturity; or • Inflation may reduce the effective yield on the bond’s interest payments. Risks Specific to the Energy Infrastructure Strategy Risks associated with investing in Energy Infrastructure Strategy securities include: • Concentration Risk: Most MLP investments are concentrated in the natural resource infrastructure and processing industries. This investment strategy tends to be nondiversified. Thus, clients participating in this strategy will be substantially concentrated in one sector of the economy. Additionally, because of the limited number of MLPs and midstream related companies that fit the investment objective, clients and the Energy Infrastructure Partnerships may at certain time hold large positions in a relatively limited number of investments. Clients and the Energy Infrastructure Partnerships could be subject to significant losses if they hold a large position in a particular investment that declines in value. • Management risk - the risk associated with ineffective or underperforming management. For 10  example, management may elect to overleverage or invest in volatile or under-maintaining assets. • Acquisition risk – the MLPs may not be able to access capital, thus limiting the growth prospect of the MLP. • Structure risk – investors generally have fewer rights in a limited partnership structure and general • partners of the entity may have conflicts of interest with the limited partners. Interest Rate risk – large changes in interest rates of alternative income instruments can affect MLP returns. • Regulatory risk – changes in U.S. tax regulations could negatively affect the treatment of MLP distributions. • Tax risk – MLPs do not typically pay U.S. federal income tax at the partnership level. Rather, each partner is allocated a share of the partnership’s income, gains, losses, deductions, and expenses. In extreme cases, liabilities of MLPs that are forgiven in bankruptcy could be treated as income to the MLP, which could result in tax liabilities payable by the MLP’s limited partners. While the Company has not observed such an occurrence, in the event a client’s investment in an MLP suffered significant reductions in value due to bankruptcy, it is possible that such additional tax liabilities could result in losses exceeding the value of the client’s initial investment in the MLP. Because each client’s tax situation is unique, clients should consult a tax professional about federal, state, and local consequences of MLP investments. Risks Specific to the Renewables Infrastructure Strategy Risks associated with investing in renewable infrastructure securities include: • Concentration Risk: Renewable infrastructure investments come in many forms, though as a group they tend to be highly correlated to environmental issues. Thus, clients participating in this strategy should assume investments are substantially concentrated in one sector of the economy (Clean Energy). In addition, because of the limited number of renewable infrastructure companies that fit the investment objective, clients may at certain times hold large positions in a relatively limited number of investments. Clients could be subject to significant losses if they hold a large position in a particular investment that declines in value. • • Regulatory/Geopolitical Risk: Changes in federal and/or state government administration and regulatory regimes can meaningfully impact the growth profile of renewables infrastructure investments. As an example, changes in tax incentives can alter return expectations for a growth project, and thereby influence an investment’s growth expectations. International Risk: Several companies within the renewables infrastructure universe have a global footprint, which can expose certain investments to the regulatory and political vagaries in multiple jurisdictions. Additionally, international investments come with exchange rate (currency) risk to some extent. • Counterparty Risk: Renewables infrastructure investments are typically secured with power purchase agreements (PPAs) or other forms of long-term contracts. These contracts are only as good as the counterparty and could be at risk for adjustment should conditions (i.e., bankruptcy) occur at the counterparty that makes them unable to meet contracted terms. • Operational Risk: The amount of energy – and therefore cash flow – of most renewables infrastructure assets depends on natural factors such as wind speeds and solar energy. Damage to equipment can alter the ability of any single facility to produce generation in line with long-term forecasts, and reliance on third party assets may also have an adverse impact on cash flows should these third party assets fail to operate as expected. • Management Risk: Ineffective or underperforming management teams will impact investment performance. For example, management may elect to overleverage or invest in volatile or under- maintaining assets. 11  Risks Specific to the BDC Strategy Risks associated with investing in BDC securities include: While BDCs consist mainly of portfolios of fixed income securities, the portfolios and the underlying companies can be highly levered and exposed to all types of market risk. As such they exhibit the characteristics of equity securities and fluctuate in response to issuer, political, market, and economic developments. Fluctuations can be dramatic over the short-term as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. For example, large cap stocks can react differently from small cap stocks, and "growth" stocks can react differently from "value" stocks. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo-political risks have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term effects on world economies and markets generally. In addition, the value of portfolios may fluctuate as the general level of interest rates fluctuates. Risks Specific to Eagle Scarcity Partners, LP • Limited Operating History. The fund began investing in 2024 and has a limited operating history upon which investors can evaluate the likely performance of the fund. The fund’s investment program should be evaluated on the basis that there can be no assurance that the manager’s assessment of investment opportunities or its execution of the fund’s investment approach will achieve the investment objectives of the fund. Past performance of the manager is not necessarily indicative of future results. • Digital Assets: The term “Digital Assets” generally refers to an asset that is issued and/or transferred using distributed ledger or blockchain technology, including, “virtual currencies (also known as crypto currencies),” “coins,” and “tokens”. We may invest in and/or advise clients on the purchase or sale of digital assets. This advice or investment may be via investment vehicles such as ETFs. The investment characteristics of Digital Assets generally differ from those of traditional securities, currencies, commodities. Digital Assets are not backed by a central bank or a national, international organization, any hard assets, human capital, or other form of credit and are relatively new to the marketplace. Rather, Digital Assets are market-based: a Digital Asset’s value is determined by (and fluctuates often, according to) supply and demand factors, its adoption in the traditional commerce channels, and/or the value that various market participants place on it through their mutual agreement or transactions. The lack of history to these types of investments entail certain unknown risks, are very speculative and are not appropriate for all investors. • Commodities: Investing in commodities carries risks including price volatility due to supply and demand, weather events, geopolitical factors, and market conditions, potentially leading to significant losses. We may invest in and/or advise clients on the purchase or sale of commodity investments. This advice or investment may be via investment vehicles such as ETFs or through commodity futures. Commodity investments are not appropriate for all investors. Additional risks involving an investment in the Private Funds are discussed in each Private Fund’s Private Placement Memorandum. Cybersecurity Risk The Company, its service providers and other market participants increasingly depend on complex information technology and communications systems to conduct business functions. These systems are 12  subject to a number of different threats or risks that could adversely affect clients, including Private Funds and their investors, despite the efforts of the Company and its service providers to adopt technologies, processes and practices intended to mitigate these risks and protect the security of their computer systems, software, networks and other technology assets, as well as the confidentiality, integrity and availability of information belonging to clients and/or Private Funds. For example, unauthorized third parties may attempt to improperly access, modify, disrupt the operations of, or prevent access to these systems of the Company and its service providers, counterparties or data within these systems. Third parties may also attempt to fraudulently induce employees, customers, third-party service providers or other users of the Company’s systems to disclose sensitive information in order to gain access to the Company’s data or that of clients or the Private Funds’ investors. A successful penetration or circumvention of the security of the Company’s systems could result in the loss or theft of an investor’s data or funds, the inability to access electronic systems, loss or theft of proprietary information or corporate data, physical damage to a computer or network system or costs associated with system repairs. Such incidents could cause the Private Funds, the Adviser or their service providers to incur regulatory penalties, reputational damage, additional compliance costs or financial loss. Force Majeure or Other Risks Investments may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern, war, terrorism, labor strikes, failure of technology, defective design and construction, accidents, demographic changes, government macroeconomic policies, social instability, etc.). Some force majeure events may adversely affect the ability of a party to perform its obligations until it is able to remedy the force majeure event. These risks could, among other effects, adversely impact the cash flows available from an investment, cause personal injury or loss of life, damage property, or instigate disruptions of service. In addition, the cost resulting from such force majeure events could be considerable. Force majeure events that are incapable of or are too costly to cure may have a permanent adverse effect on an investment. Certain force majeure events (such as war or an outbreak of an infectious disease) could have a broader negative impact on the world economy and international business activity generally, or in any of the countries in which Eagle Global may invest specifically. Artificial Intelligence Engines and Machine Learning (collectively “AI”) AI is used as an umbrella term that encompasses a broad spectrum of different technologies and applications. The Company defines AI as computer systems able to perform tasks that normally require human intelligence, such as visual perception, speech recognition, decision-making, and translation between languages, more commonly known as generative AI. When relying on AI there are certain risks involved, including data quality, copyright and trade secret violations, confidentiality breaches, unauthorized access or malware risks, insider trading, breach of contract, cybersecurity, and privacy law violations. Disciplinary Information The Company and its employees have not been involved in any legal or disciplinary events in the past 10 years that would be material to a client’s evaluation of the company or its personnel. Other Financial Industry Activities and Affiliations Affiliates of the Company are the General Partners and/or Manager of the Private Funds in which clients are solicited to invest. Because the Private Funds pay performance based fees, in addition to management fees, the fee structure presents an apparent conflict of interest. To address this apparent conflict of interest, Eagle 13  Global has implemented trade allocation and aggregation policies, which are discussed in the Brokerage section of this brochure. In addition, certain employees of the Company also have investments within the Private Funds. These employees pay the same management and performance fees as the other investors. An exception to this is investment vehicles comprised solely of employees at Eagle Global, which may pay no or reduced fees. A certain control person of Eagle Global is invested in a fund previously managed by Eagle Global: the EMC Alpha Fund, LP. As of July 31, 2017, this fund is managed by a separate adviser registered with the state of Texas, EMC Wealth Management, LLC. A conflict of interest exists in that Eagle Global may continue to recommend that clients invest in the EMC Alpha Fund, LP while at the same time sharing in economic interest of the general partner of those funds, as described herein under “Fees and Compensation”. To mitigate this conflict, Eagle continues to conduct diligence on this investment and make recommendations to invest in this fund only when appropriate for the client. Additionally, Eagle Global does not receive any referral fees from EMC Wealth Management, LLC for recommending clients to invest in the EMC Alpha Fund, LP. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading The Company has adopted a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act, to ensure that securities transactions by Company employees are consistent with the Company’s fiduciary duty to its clients and to ensure compliance with legal requirements and the Company’s standards of business conduct. The Code requires that employees obtain prior approval for personal securities transactions and requires transaction confirmation and quarterly reporting of such transactions. If you would like to receive a written copy of Eagle Global Advisor’s Code of Ethics, please contact Shelley Milloway at 713-952-3550. The Company’s employees are permitted to invest in the same securities that are recommended for client accounts, subject to the following restrictions. Investment Professionals may not purchase securities for their personal account until at least one day after they have purchased that security for Client portfolios that they manage. They may not sell any Security for their personal account until at least one day after they have sold that Security for Client portfolios that they manage. To prevent conflicts of interest, all employees of the Company must comply with the Company’s Compliance Manual and Code of Ethics, which imposes restrictions on the purchase or sale of securities for their own accounts and the accounts of certain affiliated persons. Records will be maintained of all securities bought or sold by the Company, employees or related entities. With the exception of records of the Company’s private fund and mutual fund clients, such client holdings and transaction records will be available for client inspection in the Company’s offices upon request. Files of securities transactions effected for employees of the Company will be maintained for review should there be a conflict of interest. All securities transactions of related persons of the Company will be reviewed by the Chief Compliance Officer or his designee to ensure no conflicts exist with client executions. Additionally, certain of Eagle Global’s employees or related parties will have an investment in the Private Funds. For example, the General Partner for the Energy Infrastructure Partnerships is 100% owned by members of Eagle Global Advisors, LLC. Therefore, Eagle Global, its employees, or a related entity participate in transactions effected for Private Funds. Eagle Global will also solicit clients to invest in the Private Funds. Recommendations will only be made to clients who are qualified to invest in the Private Funds and the investment is suitable with the client’s investment objectives. 14  Brokerage Practices Selection of Brokers In the allocation of brokerage business, the Company may give preference to those brokers or dealers who provide research or brokerage services to the Company, either directly or through third parties. Such services may be purchased using credits generated through the execution of client securities transactions, known as “soft dollars.” Research services may include advice, either directly or through publications or writings, as to the value of securities, the advisability of investing in, purchasing, or selling securities, and the availability of securities or purchasers or sellers of securities; and analyses and reports concerning issues, industries, securities, economic factors and trends, portfolio strategy, earnings estimate databases, valuation databases, and the performance of accounts. Thus, the Company may be able to supplement its own information and to consider the views and information of other organizations in arriving at investment decisions. Brokerage services may include a dedicated trading desk that services Eagle Global’s clients, a dedicated service group and an account services manager dedicated to the Company’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, and duplicate and batched client statements. If such information and services are received and are in fact useful to the Company, it may tend to reduce the Company’s normal and customary need to devote resources to brokerage and research activities. All products and services received will benefit all client accounts, although some clients may benefit to a greater or lesser extent than others. Additionally, certain clients’ trading activities may not generate soft dollar credits due to directed brokerage or other arrangements. Because the Company uses research and brokerage services to enhance its investment due diligence and execution capabilities generally, such clients will likely benefit from research and brokerage services purchased using soft dollars generated by other client accounts. The Company limits its use of soft dollars to purchase services within the safe harbor provisions of Section 28(e) of the Securities Exchange Act of 1934. Section 28(e) of the Securities Exchange Act of 1934 provides a "safe harbor" for investment managers who use commission dollars of their advised accounts to obtain investment research or brokerage services that provide lawful and appropriate assistance to the manager in performing investment decision-making responsibilities and executing client transactions. Payment for such services with commission dollars is in all events limited to the portion of the costs of such services that are relevant to the investment decision-making and execution processes of the Company. However, using commission dollars to obtain these products and services provides the Company a benefit because it does not have to produce or pay for the research, products or services. When the Company uses soft dollars to pay for a service used for different purposes, the portion of the service used in the investment decision-making or execution processes is determined through a survey of employees regarding their use of the service. The Company pays for portion of the service falling outside the Section 28(e) safe harbor with hard dollars; alternatively, the Company may pay for such services entirely with hard dollars. Currently only agency trades and no principal trades are used in connection with payment for these services. Soft dollar arrangements give the Company an incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than our clients’ interest in receiving the most favorable execution. Client Directed Brokerage In some instances, clients have directed the Company to use a specified broker or dealer for portfolio transactions for such client’s account, even though such broker or dealer charges commission rates in excess of the institutional rates generally available to the Company. The Company will follow the client’s direction as long as the client understands that under such an arrangement (i) the ability of the Company to negotiate commissions on the client’s behalf will be limited and as a result, the client will likely pay higher commission rates and disparate commission rates depending on the client’s commission arrangement with such broker or 15  dealer, and (ii) the ability of the Company to “batch” the client’s order with the orders of other clients will be limited so that the opportunity to achieve reduced commission rates or better executions may be lost to the client. The client using such an arrangement must understand that should the Company be free to select a broker or dealer, to negotiate for institutional commission rate and to “batch” orders, the client might pay rates below customary retail brokerage rates and might achieve better executions. In certain situations, the Company may seek to meet directed brokerage mandates by stepping out trades batched with other client orders for execution to a directed broker for settlement. The Company is under no obligation to execute directed brokerage trades through the use of step-out trades and will not do so if it determines that the practice is detrimental to execution costs or quality of clients that do not direct brokerage. Although the Company will attempt to effect directed brokerage transactions in a manner consistent with its policy to seek prompt execution of orders in an efficient manner at a favorable price, its ability to obtain best execution for these transactions may be affected. Some of the Company’s clients have selected a broker-dealer to act as custodian for the client’s assets and direct the Company to execute transactions through that broker-dealer. It is not the practice of the Company to negotiate commission rates with such broker-dealers. When clients open a custodial account with a bank trust company and grant the Company discretion to select a broker-dealer, the Company will make a best effort to obtain the best brokerage commission rate possible under the circumstances. Clients directing brokerage pay higher brokerage commissions than would be paid when the Company is free to determine the best available broker and the Company is not be able to aggregate directed brokerage orders with orders for its other client accounts. Accordingly, clients directing brokerage to a particular broker-dealer should consider whether the commissions, executions, clearance and settlement capabilities and fees for custodial or other services provided to the client by that broker-dealer (if applicable) will be comparable to those otherwise obtainable. The Company does expect custodial and brokerage firms to meet minimum requirements for operational efficiency and therefore not all custodial and brokerage firms will be acceptable to the Company. The Company also reserves the right to not accept a designated broker-dealer where it does not already have a working relationship. Trade Aggregation and Allocation The Company considers a number of factors when determining to purchase or sell a security for a particular client account. These factors include, but are not limited to: Investment objective, policies and strategy of the account; • • Appropriateness of the investment to the account's time horizon and risk objectives; • Existing levels of ownership of the investment and other similar securities; and, • The immediate availability of cash or buying power to fund the investment. The Company utilizes a randomly generated Trade Rotation to determine the trade order when trades will be allocated via multiple orders to multiple counterparties. Trades will be directed by the trader to the applicable broker-dealer in blocks or bunches, based on the trade rotation. The clients participating in each bunch or block will be allocated the average cost per trade experienced with the counterparty with which the client’s bunch was executed. The Company maintains records that specify the client accounts that are participating in the rotation and the amount of securities intended to be purchased or sold for each account. Clients who have engaged Eagle Global for Research Services, as discussed above, are generally included in Eagle’s randomly generated trade rotation and treated in the same manner as any other client. However, certain clients who engage Eagle Global for Research Services and have American Depositary Receipt (“ADR”) conversion restrictions will be traded last in the Trade Rotation. Additionally, clients that have engaged Eagle Global for Energy Infrastructure Research Services will also be traded last in the trade rotation. Also, at certain times, Eagle Global is presented with the opportunity to take advantage of natural liquidity in the marketplace. Eagle Global must act in a timely manner to take advantage of the liquidity. When such situations arise, Eagle Global will generally take advantage of the liquidity in accounts that have not directed 16  the Company to use a specific broker-dealer. Therefore, these accounts will move to the top of the Trade Rotation when the natural liquidity is available. When the natural liquidity is exhausted or is no longer available, Eagle Global will return to the standard Trade Rotation process. Investments in Initial Public Offerings (“IPOs”), secondary offerings, private investments in public equities (“PIPEs”), short sales, and purely private companies are not considered part of the general strategy mandates associated with the separately managed accounts or the sub or co-advised investment companies and therefore they do not receive allocations of such securities. These securities are allocated solely to the Private Funds. The Company can engage in cross-trading between client accounts when such a transaction is in the best interest of both clients involved. Cross transactions are priced by independent brokerage firms and both sides receive the same price and equally split any transactional costs. Trade Errors It is the Company’s policy that the utmost care is taken in making and implementing investment decisions on behalf of client accounts. To the extent that any errors occur, they are to be (a) corrected as soon as practicable, (b) reported to the CCO or Partner in charge of Trading or designee and (c) scrutinized carefully with a view toward implementing procedures to prevent or reduce future errors, if necessary. In no event shall the Company’s clients bear losses incurred in connection with trade errors. Depending on the circumstances of the error, any gain resulting from a trade error may be retained by the client, the broker, or donated to charity. Review of Accounts The Company performs investment advisory security selection and portfolio recommendations for client’s advisory accounts. Accounts are typically reviewed monthly or as new transactions are considered but will be reviewed no less frequently than quarterly. A more frequent review may also be instigated by a client inquiry due to changes in investment objectives or risk tolerance. Reviews will be performed by the Partners, Portfolio Managers and Senior Vice Presidents of Eagle Global. Investment reports will be provided on a quarterly basis to inform clients or clients’ consultants of the performance of their investments for the selected period. Additional reports will be prepared at the client’s discretion. Clients or clients’ consultants are provided with a comprehensive annual investment review, including current investment recommendations. The client or clients’ consultants will continue to receive statements from the custodian or broker/dealer of the accounts. However, clients whose accounts are managed by the Company through a sub or co-advisory relationship may not receive such reports. With respect to the Private Funds, the holdings of such Private Funds are reviewed daily by the investment team responsible for the Private Funds. Investment reports are provided on a monthly and quarterly basis to investors or investors’ consultants informing them of the performance of their investment for the select period. Client Referrals and Other Compensation The Company compensates third parties and employees who refer clients to the Company. If the Company accepts a new client who is introduced to the Company by a third party promoter, the Company will pay such third party promoter a placement fee that is based upon the assets the client places with the Company. All client referrals from a promoter will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, and any other applicable state or regulatory requirements. 17  Custody All client assets are held in custody by unaffiliated broker/dealers or banks; but the Company can access certain client funds through its ability to debit advisory fees. For this reason, the Company is considered to 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 account information provided by the Company. Eagle Global is also deemed to have custody over the Private Funds since an affiliate serves as the General Partner and/or Manager of the Private Funds. Limited partners of the Private Fund will not receive statements from the custodian. Instead the Partnership is subject to an annual audit and the audited financial statements are distributed to each investor. The audited financial statements will be prepared in accordance with generally accepted accounting principles and distributed within 120 days of the partnership’s fiscal year end. Investment Discretion The Company manages client accounts on a discretionary basis, subject to the restrictions (if any) that have been provided by clients. Eagle Global also provides research and model investment recommendations with respect to the assets of third party advisors. For accounts handled on a discretionary basis, the Company typically has the authority to determine the securities to be bought and sold without obtaining client consent to specific transactions. Moreover, in the accounts handled on a discretionary basis, the Company typically has the authority to determine the amount of the securities to be bought and sold without obtaining client consent to specific transactions. Discretionary authority will be granted through the execution of an investment advisory agreement with each client. Voting Client Securities It is the policy of the Company to vote proxies that it receives for all accounts for which it has voting authority and in a manner in which the Company believes it to be in the best interests of its clients. Clients should make reasonable efforts to instruct their custodian to promptly forward all proxy voting ballots to Eagle Global. The Company will also make a reasonable effort to contact a custodian if Eagle Global believes that the custodian may not be appropriately sending relevant proxy ballots to the Company. Nonetheless, Eagle Global can only vote proxies that it receives. Eagle Global has provided proxy voting guidelines to Institutional Shareholders Services (ISS), our proxy advisory firm. ISS provides proxy voting recommendations based on these guidelines. When Eagle guidelines are inadequate for the basis of a voting recommendation, ISS provides a voting recommendation based on their own research. In the absence of both, the proxy is voted with the recommendations of the issuer’s existing management. A written copy of the proxy policies and procedures as well as information about how proxies for a client or investor’s shares were voted are available upon request by calling the number on the cover page of this brochure. The Company has developed policies and procedures for the identification and resolution of conflicts of interest when voting proxies. The Company’s Proxy Administrator periodically reviews client holdings to identify potential conflicts of interest. Potential conflicts of interest will be reported to the Eagle Global CCO for a final determination. If a conflict is determined to exist, the Proxy Administrator will vote in accordance with the Company’s Proxy policies or, if intending to vote in a manner inconsistent with the Proxies policies, seek instruction from the client, mutual fund board, or the adviser if the Company serves as sub or co-adviser. The Company will generally abstain from voting the proxy if the client, fund board, or adviser fails to instruct the Company on how to vote. If “Class Action” documents are received by the Company on behalf of its Private Funds, the Company will ensure that the Private Funds either participate in, or opt out of, any class action settlements received. The 18  Company will determine if it is in the best interest of the Private Funds to recover monies from a class action. If the anticipated proceeds of the class action settlement are considered material (greater or equal to 1.0% of the Private Fund), a receivable will be added to the Private Fund for the date of the claim. All investors in the Private Fund at the point of adding the receivable will be eligible for their prorated portion of any realized proceeds. Investors that fully withdraw from the Private Fund after the receivable is added will remain in the Private Fund until the claim is realized. If the anticipated proceeds are not considered material a receivable would not be added to the Private Fund. These proceeds are distributed amongst the investors in the partnership at the time of receipt of proceeds. Eagle Global will not act on behalf of those Separately Managed Account (“SMA”) clients or investment companies that receive Class Actions notices under any circumstance. If the Company receives class action documents on behalf of an SMA client and/or investment companies, Eagle Global will forward to the client any requisite information it has relating to the Class Action. Financial Information The Company has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts. 19