RUNDE & CO. LLC

Item 1 – Cover Page Runde & Co. LLC Form ADV Part 2A: Firm Brochure 1420 5th Avenue Suite 2200 Seattle, WA 98101 www.rundeinvestmentmanagement.com Telephone: 206-323-2255 March 31, 2025 This Brochure provides information about the qualifications and business practices of Runde & Co. LLC. If you have any questions about the contents of this Brochure, please contact us at 206-323-2255 or elizabeth@rundeinvestmentmanagement.com. 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. Runde & Co. LLC is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications we provide you including this Brochure is information you use to evaluate us, which are factors you determine to hire or retain us. Additional information about Runde & Co. LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 106383. i  Item 2 – Material Changes This Brochure, dated March 31, 2025, is prepared in accordance with the SEC’s rules and requirements. Item 2 discusses only specific material changes that have been made since the last annual update to the Brochure and provides a summary of such changes. There are no material changes since March 31, 2024. Our Brochure may be requested by contacting our Chief Compliance Officer at 206-323- 2255. ii  Item 3 -Table of Contents Page Item 1 - Cover Page ................................................................................................................................................ i Item 2 - Material Changes .................................................................................................................................. ii Item 3 - Table of Contents ................................................................................................................................ iii Item 4 - Advisory Business ................................................................................................................................ 1 Item 5 - Fees and Compensation ..................................................................................................................... 1 Item 6 - Performance-Based Fees and Side-By-Side Management .................................................... 2 Item 7 - Types of Clients ..................................................................................................................................... 2 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss............................................. 2 Item 9 - Disciplinary Information ................................................................................................................... 4 Item 10 - Other Financial Industry Activities and Affiliations ............................................................. 4 tem 11 - Code of Ethics ....................................................................................................................................... 4 Item 12 - Brokerage Practices .......................................................................................................................... 5 Item 13 - Review of Accounts ........................................................................................................................... 6 Item 14 - Client Referrals and Other Compensation................................................................................ 6 Item 15 - Custody .................................................................................................................................................. 6 Item 16 - Investment Discretion ..................................................................................................................... 6 Item 17 - Voting Client Securities ................................................................................................................... 7 Item 18 - Financial Information ....................................................................................................................... 7 Brochure Supplement iii  Item 4 – Advisory Business Runde & Co. LLC is an independent, SEC registered investment advisor offering investment management services. The Runde & Co. LLC investment team is led by Elizabeth G. A. Runde and Kevin Casey Runde who have more than 80 years combined investment experience. Investments are made in stocks, bonds and mutual funds. Runde & Co. LLC is owned and operated by Elizabeth Runde (51%) and Casey Runde (49%). The firm, formerly known as Runde & Co. Incorporated was founded in 1992 by Elizabeth Runde and Casey Runde. Runde & Co. LLC seeks to achieve solid risk-adjusted investment returns for its investors through the construction and management of highly diversified portfolios of equity securities. The investment strategy is a fundamentally based, process-driven investment approach. Runde’s objective methodology, based on a proprietary filter developed in-house, is designed to identify undervalued and overvalued stocks. There are a number of benefits to a process-driven investment strategy and specifically to the Runde strategy. The primary benefit is that the Runde implementation creates and facilitates a dispassionate, unbiased approach to investing which is replicable and in which stock selection criteria can be uniformly applied. A secondary benefit is that a systematic approach allows for greater diversification of the assets which contributes to better risk- adjusted performance and a reduction of the company-specific risks inherent in the marketplace. Lastly, Runde portfolios have very low turnover. Investment advice is limited to stocks, bonds and mutual funds. Client portfolios are tailored to specific needs through asset allocation. Asset allocation is established for each client and reviewed regularly. For some clients, bonds and mutual funds are included in their overall asset allocation. Clients are able to impose restrictions on investing in certain securities when they sign the Runde & Co. LLC suitability agreement. Runde & Co. LLC has assets under management of $185 million as of 12/31/2024. Item 5 – Fees and Compensation All fees are subject to negotiation without qualification. The specific manner in which fees are charged by Runde & Co. LLC is established in a client’s written agreement with Runde & Co. LLC. Runde & Co. LLC bills its fees on a quarterly basis in arrears. Clients may request in writing to be billed in advance. Clients may elect to be billed or to arrange with their custodians to allow Runde & Co. LLC to directly debit fees from client accounts. Management fees shall be prorated for each capital contribution and withdrawal made during the applicable calendar quarter (with the exception of contributions and withdrawals less than $10,000.00). Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account, 1  any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Runde & Co. LLC's fee per annum on the assets under management is • 1% on the first $2,000,000 • 0.75% on the next $3,000,000 • 0.50% on all over $5,000,000 Runde & Co. LLC’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Runde & Co. LLC’s fee, and Runde & Co. LLC shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that Runde & Co. LLC considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Item 6 – Performance-Based Fees and Side-By-Side Management Runde & Co. LLC does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients Runde & Co. LLC provides portfolio management services to the following types of clients: • High net worth individuals • Foundations • Corporate pension and profit-sharing plans • Other investment advisers There are no requirements for opening or maintaining an account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. 2  Investment Philosophy: Runde & Co. LLC seeks to achieve solid risk-adjusted investment returns for its investors through the construction and management of highly diversified portfolios of equity securities. The investment strategy is a fundamentally based, process-driven investment approach. Runde’s objective methodology, based on a proprietary filter developed in-house, is designed to identify undervalued and overvalued stocks. There are a number of benefits to a process-driven investment strategy and specifically to the Runde strategy. The primary benefit is that the Runde implementation creates and facilitates a dispassionate, unbiased approach to investing which is replicable and in which stock selection criteria can be uniformly applied. A secondary benefit is that a systematic approach allows for greater diversification of the assets which contributes to better risk- adjusted performance and a reduction of the company-specific risks inherent in the marketplace. Lastly, Runde portfolios have very low turnover and are therefore highly tax- efficient. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly- available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investment Strategy: Runde & Co. LLC currently offers seven portfolios that employ the strategy and derive the benefits described above. They are as follows: Runde Core Strategy: Runde Core Strategy is an earnings-driven strategy. Investing in equity securities involves risk of loss that clients should be prepared to bear. Runde offers the following core portfolio: • Runde Large-Cap Core Runde Value Strategy: Runde Value Strategy is a dividend-driven strategy. Investing in equity securities involves risk of loss that clients should be prepared to bear. Runde offers the following value portfolios: • Runde Large-Cap Value • Runde Small/Mid-Cap Value Runde International Value Strategy: Runde International Value Strategy is a dividend- driven strategy. Investing in equity securities involves risk of loss that clients should be 3  prepared to bear. Runde offers the following international value portfolios: • Runde International Large-Cap Value • Runde International Small-Cap Value • Runde Emerging Markets Value Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of their advisory business or the integrity of their management. Runde & Co. LLC has no information applicable to this item. Item 10 – Other Financial Industry Activities and Affiliations Runde & Co. LLC is not actively engaged in a business other than giving investment advice and has no industry affiliations. Runde acts as a sub-advisor to a multi-strategy investment firm (Xponance). There are no fee arrangements between Runde & Co. LLC and any other advisers. This arrangement does not create any material conflict of interest. Item 11 – Code of Ethics Runde & Co. LLC has adopted a Code of Ethics for all employees of the firm describing its high standard of business conduct. All employees at Runde & Co. LLC must acknowledge the terms of the Code of Ethics annually, or as amended. Runde & Co. LLC anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which Runde & Co. LLC has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which Runde & Co. LLC’s clients, directly or indirectly, have a position of interest. Runde & Co. LLC’s employees are required to follow Runde & Co. LLC’s Code of Ethics. Subject to satisfying the Runde Personal Trading Policy and applicable laws, employees of Runde & Co. LLC may trade for their own accounts in securities which are recommended to and/or purchased for Runde & Co. LLC’s clients. The Code of Ethics, in conjunction with the Personal Trading Policy, is designed to assure that the personal securities transactions, activities and interests of the employees of Runde & Co. LLC will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Because the Personal Trading Policy permits employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Therefore, employees must adhere to certain procedures and restrictions when trading in close proximity to client 4  trading activity. Specifically, when buying and selling stocks in the US Markets, personal security transactions will be made after client transactions have been made. However, when buying and selling in the Foreign Markets, client and personal trades may be executed simultaneously and allocated to all at the average price. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between Runde & Co. LLC and its clients. Certain client accounts may trade in the same securities with other client accounts on an aggregated basis when consistent with Runde & Co. LLC's obligation of best execution. In such circumstances, client accounts receive securities at a total average price. Runde & Co. LLC will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. Runde & Co. LLC does not affect any principal cross securities transactions for client accounts and does not cross trades between client accounts. Runde & Co. LLC’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Elizabeth Runde 206-323-2255 or elizabeth@rundeinvestmentmanagement.com. Item 12 – Brokerage Practices Runde & Co. LLC does not have any soft-dollar arrangements and does not receive any soft- dollar benefits. In selecting the broker, such selection is made on the basis of (1) trading capability with respect to the particular security, (2) ability to obtain most favorable pricing and (3) extent of discount allowed from published commission rates. Runde & Co. LLC may pay a broker a brokerage commission in excess of that which another broker might have charged for effecting the same transactions in recognition of (1) and (2). During the last year, pursuant to internal allocation procedure and subject to considerations (1) through (3) above, Runde & Co. LLC has directed transactions to between 1-5 firms, the number of which varies yearly, based on considerations discussed herein. The goal is to obtain transactions representing the best qualitative execution for the client, based on such factors as the efficiency of execution, the timing of the transaction, the price of the security purchased or sold, the commission rate, the financial responsibility of the brokerage firm and the brokerage firm’s responsiveness to the investment advisor. From our primary broker, Charles Schwab, we receive custody, record keeping, advisory 5  bulletins and compliance manuals all of which are applicable to each of our clients. As our primary broker, they maintain prime broker agreements with over 400 executing broker/dealers with whom we are allowed to transact. The prime broker service fee Schwab charges is $25 per trade allocation. Item 13 – Review of Accounts Elizabeth G.A. Runde, President, and Kevin Casey Runde, Chief Investment Officer, share responsibility for reviewing the securities in all managed portfolios and the allocation of assets within each portfolio. News affecting each security is monitored daily. Portfolio composition and investment performance are reviewed at least monthly but more frequently when dictated by unexpected economic or market events. Performance variance among similar portfolios would be a triggering factor to have an interim account review. On a quarterly basis, our clients receive a report from Runde & Co. LLC. Included in the quarterly reports are the following: 1) Asset Allocation, 2) Portfolio Performance Review, 3) Statement of Assets which shows segregation of holdings by classes of securities, cost, market value, percent of account committed to each class and security and estimated yield. 4) Investment Advisory Invoice which shows the investment management fees for the quarter. 5) Realized Gain and Losses Report (Year End Only) which shows realized gains and losses for the prior year. Item 14 – Client Referrals and Other Compensation Runde & Co. LLC does not, directly or indirectly, compensate any person for client referrals. Runde & Co. LLC is not paid cash by nor receives any economic benefit (including commissions, equipment or non-research services) from a non-client in connection with giving advice to clients. Item 15 – Custody Runde & Co. LLC’s clients should receive monthly statements from the qualified custodian that holds and maintains client’s investment assets. Runde & Co. LLC urges its clients to carefully review such statements and compare such official custodial records to the account statements that Runde & Co. LLC provides. Please note: client Statements of Assets may vary slightly from custodial statements as a result of accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion Runde & Co. LLC receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought of sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated 6  investment objectives for the particular client account. Investment discretion is granted through the signing of the Runde & Co. LLC Investment Management Agreement. Investment guidelines and restrictions must be provided to Runde & Co. LLC in writing. When selecting securities and determining amounts, Runde & Co. LLC observes the investment policies, limitations and restrictions of the clients it advises. Item 17 – Voting Client Securities Runde & Co. LLC votes proxies for those accounts which have given the advisor voting authority. Investment Advisors Act of 1940 Rules 206(4)-6 imposes a number of requirements on investment advisers that have voting authority with respect to securities held in their clients’ accounts. The SEC states that the duty of care requires an adviser with proxy voting authority to monitor corporate actions and to vote the proxies. To satisfy its duty of loyalty, an advisor must cast the proxy votes in a manner consistent with the best interests of its clients, and must never put the adviser’s own interests above those of its clients. These written policies and procedures are designed to reasonably ensure that the adviser votes proxies in the best interest of clients for whom the adviser has voting authority and describes how the adviser addresses the material conflicts between its interests and those of its clients with respect to proxy voting. Runde & Co. LLC has hired Broadridge to assist in the process of voting and maintaining records of how each proxy has been voted for our clients. Runde & Co. LLC is responsible for deciding what is in the best interest of clients when determining how proxies are voted. We define the best interest of the client to mean best economic interest of the shareholders of the company. Because circumstances differ between clients, some clients reserve the right to vote their own proxies. Clients may obtain a copy of Runde & Co. LLC’s complete proxy voting policies and procedures upon request. Clients may also obtain information about how Runde voted any proxies on behalf of their accounts. Item 18 – Financial Information Runde & Co. LLC is required in this item to provide certain financial information or disclosures about Runde & Co. LLC’s financial condition. Runde & Co. LLC has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. 7 

Item 1- Cover Page Elizabeth Gilbert Anderson Runde CRD Number 2319412 Runde & Co. LLC 1420 5th Avenue Suite 2200 Seattle, WA 98101 Telephone: 206-323-2255 March 31, 2025 This Brochure Supplement provides information about Elizabeth Gilbert Anderson Runde that supplements the Runde & Co. LLC Brochure. You should have received a copy of that Brochure. Please contact us at 206-323- 2255 or elizabeth@rundeinvestmentmanagement.com if you did not receive Runde & Co. LLC’s Brochure or if you have any questions about the contents of this supplement. Additional information about Elizabeth Gilbert Anderson Runde is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2- Educational Background and Business Experience Elizabeth Gilbert Anderson Runde (b. 1958) Educational Background MBA, International Finance, New York University – 1986 BA, Economics, Connecticut College - 1981 Business Background: Runde & Co. LLC - Seattle - President (1992 - present) Any person associated with Runde & Co. LLC (other than clerical or administrative persons) should have a college education with experience in business or investment securities research and portfolio management. Item 3- Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 4- Other Business Activities Registered investment advisers are required to disclose all material facts regarding any other business activities that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 5- Additional Compensation Registered investment advisers are required to disclose all material facts regarding any additional compensation received by supervised persons. This would include any economic benefit provided to the supervised person other than the supervised person’s regular salary, profit sharing and bonus. No information is applicable to this Item. Item 6 - Supervision  Item 1- Cover Page Kevin Casey Runde CRD Number 1363779 Runde & Co. LLC 1420 5th Avenue Suite 2200 Seattle, WA 98101 Telephone: 206-323-2255 March 31, 2025 This Brochure Supplement provides information about Kevin Casey Runde that supplements the Runde & Co. LLC Brochure. You should have received a copy of that Brochure. Please contact us at 206- 323-2255 or elizabeth@rundeinvestmentmanagement.com if you did not receive Runde & Co. LLC’s Brochure or if you have any questions about the contents of this supplement. Additional information about Kevin Casey Runde is available on the SEC’s website at www.adviserinfo.sec.gov  Item 2- Educational Background and Business Experience Kevin Casey Runde (b. 1955) Educational Background MBA, Finance, New York University – 1984 BBA, Finance, University of Wisconsin - 1978 Business Background: Runde & Co. LLC - Seattle - Chief Investment Officer (1992 - present) Any person associated with Runde & Co. LLC (other than clerical or administrative persons) should have a college education with experience in business or investment securities research and portfolio management. Item 3- Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 4- Other Business Activities Registered investment advisers are required to disclose all material facts regarding any other business activities that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 5- Additional Compensation Registered investment advisers are required to disclose all material facts regarding any additional compensation received by supervised persons. This would include any economic benefit provided to the supervised person other than the supervised person’s regular salary, profit sharing and bonus. No information is applicable to this Item. Item 6 - Supervision