MILLER INVESTMENT MANAGEMENT, LP

Miller Investment Management, LP Firm Brochure One Tower Bridge 100 Front Street, Suite 1400 West Conshohocken, PA 19428 Tel. 610.834.9820 www.millerinv.com March 31, 2025 This brochure provides information about the qualifications and business practices of Miller Investment Management, LP (“MIM”). If you have any questions about the contents of this brochure, please contact us at (610) 834-9820. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or any state securities authority. Additional information about MIM is available on the SEC’s website at https://adviserinfo.sec.gov/ MIM is registered with the SEC as an investment adviser. SEC registration does not require that firms satisfy specific skill or training criteria and therefore registration does not imply that any particular skill or training level has been met. Miller Investment Management, LP One Tower Bridge | 100 Front Street, Suite 1500 | West Conshohocken, PA 19428 Tel: 610.834.9820 | Fax: 610.834.9824 | www.millerinv.com  Firm Brochure Material Changes to ADV MIM reviews and updates its brochure at least annually to confirm that it remains current. The purpose of this page is to inform you of material changes since the last annual update to this brochure. If you are receiving this brochure for the first time, this section may not be relevant to you. Updates made April 30, 2024 • Advisory Business – updated assets under management Updates made March 31, 2025 • Advisory Business – updated assets under management • The Brochure Supplement has been updated to reflect personnel changes. • Clarifications were made throughout the document. The only material changes that have occurred since the last annual update on March 28, 2024, are noted above. Firm Brochure | Page 2  Firm Brochure Table of Contents Advisory Business.................................................................................................................................. 4 Fees and Compensation ....................................................................................................................... 6 Performance-Based Fees & Other Compensation ............................................................................. 7 Types of Clients ..................................................................................................................................... 7 Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 8 Disciplinary Information .................................................................................................................... 10 Other Financial Industry Activities and Affiliations ........................................................................ 10 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 11 Brokerage Practices ............................................................................................................................. 12 Review of Accounts ............................................................................................................................. 13 Client Referrals and Other Compensation ....................................................................................... 13 Custody ................................................................................................................................................. 14 Investment Discretion......................................................................................................................... 14 Voting Client Securities...................................................................................................................... 15 Financial Information ......................................................................................................................... 15 Brochure Supplement......................................................................................................................... 15 Elwyn Evans, III, Consultant................................................................................................ 16 Edward A. Glickman ............................................................................................................. 17 Daniel J. Harnish ................................................................................................................... 17 Timothy Letter ....................................................................................................................... 18 H. Scott Miller ........................................................................................................................ 19 Henry S. Miller, Jr. ................................................................................................................ 19 Clayton P. Parrett .................................................................................................................. 20 Matthew J. Ryan ..................................................................................................................... 20 Firm Brochure | Page 3  Firm Brochure Advisory Business Miller Investment Management, LP (MIM) was founded in 1998 by H. Scott Miller. The General Partner of MIM is Miller Investment Management LLC, whose sole member is Strategic Advisors International, Inc., a corporation which is wholly owned by H. Scott Miller. MIM is an SEC-registered investment adviser that provides investment advisory and supervisory services. As reasonably requested by a client, MIM will consult with the client and the client’s professional advisors as to various financial and tax matters; however, MIM does not render legal advice and does not offer financial planning, legal, tax or accounting services as a business line. Client asset allocations are established after the client’s risk tolerance, goals and objectives are assessed by MIM. Although not the norm or recommended by MIM, clients may impose restrictions on the size of an allocation to a certain asset class, the types of asset classes in which the client is invested, and the nature of the investments used. MIM selects mutual funds, exchange traded funds, active managers and/or specific securities in accordance with the established asset allocation for each client. In general, the active managers selected will be unaffiliated with MIM. MIM has created pooled investment entities (“Private Funds”) such as limited liability companies or limited partnerships, which it has made available to its clients if they meet the qualification and investment criteria for such entities and when consistent with the client’s stated investment objectives, tolerance for risk, and liquidity requirements. These Private Funds invest in public securities, private equity and real estate. MIM, or MIM-controlled entities, serve as the general partner, investment adviser and/or manager of these Private Funds. In no case will MIM use its discretionary authority over client accounts, without confirmatory written authorization from its clients, to invest client assets in any entity established by MIM or of which MIM or a related party is a general partner, manager or investment adviser. Most of these Private Funds are currently not accepting new investors. For more details on Private Funds where MIM, or an entity controlled by MIM, serves as the general partner, manager and/or investment adviser see also other sections within this brochure such as Fees and Compensation, Performance Based Fees, & Other Compensation, Methods of Analysis, Investment Strategies and Risk of Loss, and Other Financial Industry Activities and Affiliations as well as each individual Private Fund’s confidential private offering memorandum or similar documents. When MIM recommends investing retirement assets in one of its Private Funds, provides investment advice regarding a client’s retirement plan account or individual retirement account or makes a recommendation regarding a rollover and is compensated, MIM is a fiduciary within the meaning of Title I of the Employee Retirement Income Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) and adheres to certain requirements to avoid engaging in a prohibited transaction. Characterization as an ERISA fiduciary results in MIM having a duty of loyalty (must act in the client’s best interest) and a duty of care (must act with the care, skill and diligence of a professional). In order to avoid the penalty imposed on prohibited transactions, MIM’s fee must be reasonable. Firm Brochure | Page 4  Firm Brochure MIM also offers the following retirement consulting services for retirement plans: analysis of provider fees, assistance with developing an investment policy statement for the plan, recommendation and review of a list of investment options, identifying an investment line-up that meets the diversification guidelines mandated by section 404(c)(1) of ERISA and industry benchmarking for retirement plans of similar size, services or type. In providing these services to retirement plan trustees or administrators, MIM will not act as, nor assume any of the duties of, a trustee or the plan administrator (as defined in ERISA). MIM will under no circumstance have custody or control of any of the assets of the retirement plan. MIM requires a BA, BS or comparable degree and business, legal or investment experience (minimum of 5 years) for individuals determining or giving investment advice to clients. MIM’s Investment Strategy Committee (“Committee”) provides valuable guidance to MIM on current and projected market and economic conditions. The Committee also makes recommendations on the positioning of investment portfolios to benefit from those conditions and provides its members’ views regarding general asset allocation. However, final investment decisions for client accounts are made by the Portfolio Management Committee (see Brochure Supplement). All Investment Strategy Committee members have an ownership interest in MIM. The Committee is made up of the following individuals: Dr. Lawrence Chimerine (year of birth - 1940) - BS, Brooklyn College (1961); Ph.D., Brown University (1965); Founder & President, Radnor International Consulting, 1990 to present; Managing Director, Economic Strategy Institute, 1991 to 1999; Chairman, CEO & Chief Economist, The WEFA Group, 1987 to 1990; Chairman, CEO & Chief Economist, Chase Econometrics, 1979 to 1987. Paul J. Isaac (year of birth - 1950) - BA, Williams College (1972); Portfolio Manager & Principal, Arbiter Partners, LP, 2001 to present; Chief Investment Officer, Cadogan Management, 1999 to 2011; Analyst, SC Fundamental, 1997 to 1999; Managing Director, Mabon Securities, 1991 to 1994. Roy S. Neff (year of birth - 1953) - BS, Massachusetts Institute of Technology (1974); MBA, University of Pennsylvania (1976); Partner, Gamma Capital Advisors, 2002 to 2007; Partner, Gamma Investors, LLC, 2000 to 2002; Co-CEO, BNP Cooper Neff, 1995 to 1999; Managing Partner, Cooper Neff Technologies, 1990 to 1994. Bob R. Peck (year of birth - 1966) - AB, Princeton University (1988); BA, Oxford University (1990); Managing Director, FPR Partners, LP, 2007 to present; Managing Director, The Fremont Group, 2003 to 2007; Manager, Central Investments, LLC, 1998 to 2003; Head of Public Equities, Perot Investments, 1990 to 1998. MIM does not participate in wrap fee programs. As of 12/31/2024, MIM managed $1,835,168,706 on a discretionary basis and $3,859,652,498 on a non- discretionary basis, meaning that MIM advised clients on those assets but did not have discretion over those assets. Firm Brochure | Page 5  Firm Brochure Fees and Compensation MIM is compensated by fees paid by clients. Fees charged for managing separately managed accounts (each an “SMA”) or Private Funds holding publicly traded securities and mutual funds are the greater of a percentage of the market value of the client assets under management by MIM or a minimum fee, if applicable, as stated in the advisory agreement or limited partnership agreement. The percentage fee for SMAs and such Private Funds is equal to or less than one percent (1%) per annum and may have a minimum fee as stipulated in the investment advisory agreement. Fees and expenses related to Private Funds are governed by the respective fund documents. In the case of Private Funds invested in private equity or real estate, the fees are based on contributed, committed or unreturned capital as specified in the applicable fund documents and may be as high as two percent (2%). Fees from certain Private Funds which are invested in illiquid assets have been accrued until the fund has liquidity to pay such fees. Investments in the same portfolio company may be held in more than one Private Fund. Direct expenses attributable to a Private Fund are paid from the respective funds and expenses related to more than one Private Fund are allocated pro rata across all applicable funds. In Private Funds, a performance-based fee, or carried interest, is also generally charged (see “Performance- Based Fees & Other Compensation” below). MIM Management fees are negotiable, and MIM can agree to a different Investment advisory fee structure, prorate a fee, or waive a fee entirely based upon specific facts and circumstances including, but not limited to, the client’s financial situation and circumstances, the amount of a client’s and family members’ assets under management and/or anticipated to be under management, the complexity of services provided, negotiations with the client, whether the client is a current or former employee of MIM, etc. Fees are generally charged quarterly in advance based on the average month-end value of the account for the preceding three months as reported in MIM’s portfolio accounting software which is used for billing. Timing of accrued interest, or private loans or funds held outside of a custodial account may result in a discrepancy between the value reported on the custodial statement and the portfolio accounting software which MIM utilizes to calculate client fees. MIM’s investment advisory agreement permits fees to be directly debited from client accounts. If requested, clients can be billed directly for fees. In addition to the MIM fees described in the previous paragraphs, any fees charged by the custodian of client assets will be paid by the client. Clients will also bear their proportionate share of any fees or expenses that are charged by mutual funds, sub-advisors, or investment entities in which their assets are invested. If specific securities, including exchange traded funds, are purchased or sold for clients, they incur brokerage or other transaction costs (See Brokerage Practices). A client can terminate an investment advisory contract for an SMA at any time upon thirty (30) days prior written notice. In the event of a termination, MIM will refund to the client that portion of any prepaid advisory fees that cover the period for which MIM is no longer managing the client’s assets, calculated to the date of termination. For retirement consulting services for retirement plans, MIM receives compensation through both a one- time setup fee and an annual fee based on assets in the plan. Both fees are negotiable. Firm Brochure | Page 6  Firm Brochure MIM is a licensed insurance agency in Pennsylvania (license number 927121) and has an advisor who is a licensed insurance broker (see below under “Other Financial Industry Activities and Affiliations”). MIM’s licensed insurance broker can receive commissions for the sale of insurance products to clients, and MIM shares in those commissions. Insurance activities only account for a small fraction of MIM’s revenues. As of the date of this filing, MIM has not received any insurance related commissions since 2020. The insurance commissions MIM receives are separate from any advisory fees that a client pays to MIM for investment advisory services. This presents a conflict of interest because MIM or its licensed insurance broker has an incentive to recommend insurance products as they would benefit from the commission. When recommending commissionable products to clients, MIM has a duty to recommend only products that are suitable for the client. Clients are not obligated to act on any insurance recommendations or place any transactions through MIM’s affiliated insurance broker if they decide to follow MIM’s recommendations. In the case of using other insurance brokers, MIM receives no commission or other remuneration from the sale of any insurance product. While insurance administration services can be provided by MIM’s licensed insurance broker, which in turn could result in a shared commission with MIM, there are no separate insurance administration fees paid by clients. The commission earned by MIM, as a licensed insurance agency, and its licensed insurance broker on insurance products sold are customary for such products and are in addition to the investment advisory fees paid to MIM. Performance-Based Fees & Other Compensation For certain Private Funds, MIM charges both a fixed percentage based on the amount of assets under management and a performance-based fee or carried interest. This situation causes a conflict of interest in that MIM would have higher compensation from investments in such Private Funds than from SMAs. As such, MIM would have an incentive to recommend an investment in such a Private Fund or could focus more management attention and/or put higher growth investments in such Private Funds. This conflict of interest similarly arises for an account that pays a different management fee than another account, especially if a client can choose to be invested in either account. With respect to Private Funds with performance-based fees, paid to MIM or an affiliate of MIM, MIM mitigates this conflict of interest by not using its discretionary authority over client accounts to invest in such funds, and investing client assets in such funds only with confirmatory written authorization from its clients. Types of Clients MIM provides investment advisory services to pension and profit-sharing plans, business entities, charitable organizations, foundations, endowments, Private Funds, trusts, estates and individuals. SMAs are managed in accordance with the investment objectives set by the client. On the other hand, the Private Funds are managed only in accordance with each Private Fund’s investment objectives and are not tailored to any particular fund investor’s investment objectives. Since MIM does not provide individualized advice to Private Fund investors, they should consider whether a particular Private Fund meets their investment objectives and risk tolerance prior to investing. Information about each Private Fund can be found in its confidential private offering memorandum or similar offering documents. This Firm Brochure | Page 7  Firm Brochure disclosure brochure is designed solely to provide information about MIM and should not be considered to be an offer of an interest in any MIM Private Fund. MIM also provides consulting services to the trustees and administrators of retirement plans as well as to certain portfolio companies in select Private Funds. Methods of Analysis, Investment Strategies and Risk of Loss MIM uses both fundamental and technical security analysis. It obtains information from financial newspapers and magazines, research materials prepared by others, and corporate rating service reports. It also analyzes annual reports, filings with the Securities and Exchange Commission, prospectuses and corporate financial statements, forecasts and press releases, as well as primary information such as government statistics. A primary source of information MIM uses to guide investment decisions is the accumulated knowledge and professional expertise of the Investment Strategy Committee (see “Advisory Business” above). In general, MIM buys investment assets with a long-term focus (held for more than 1 year); however, investments are held for less than 1 year if market conditions warrant. Some MIM limited partnership agreements and some client investment advisory agreements permit the use of additional investment strategies. When deemed appropriate and permitted in the governing advisory agreement or limited partnership agreement, MIM may utilize strategies such as trading (holding securities for less than 30 days), short sales, margin transactions, and option strategies, including covered options, uncovered options and spread strategies. Strategies vary from client to client for portfolios invested in public securities, based upon the client's investment objective and information provided by, and opinions of, MIM's Investment Strategy Committee, research by MIM's staff, and, ultimately, the decisions made by MIM's Portfolio Management Committee (see Brochure Supplement) and General Partner. Private Funds where MIM serves as the general partner or investment adviser have various strategies, objectives and risks which are addressed in their respective confidential private offering memoranda and related documents. Investing in securities involves risk of loss that any client should be prepared to bear, as securities can decline in value. Using short-term purchases and trading can create a higher tax burden than purchasing and holding a security for longer than one year. MIM may engage in short sales or margin transactions only if permitted by the applicable agreement (investment advisory agreement or Private Fund partnership agreement) and with client permission and adequate disclosure. In addition, hedge fund managers used by Private Funds or mutual fund managers use these techniques for assets managed by them. In such cases, accounts will incur margin interest charges due to margin transactions or items such as short-term cash flow needs to support trade implementation (i.e., temporary cash shortfall due to different settlement dates). With these exceptions, MIM does not use leverage or short sales for its general client base. The use of margin creates leverage, which increases returns if the investor using leverage earns a greater return on investments purchased with borrowed funds than the investor’s cost of borrowing such funds. However, the use of leverage exposes the investor to additional levels of risk, including (i) losses because the investment fails to earn a return that equals or exceeds the investor’s cost of borrowing, (ii) greater losses from investments than Firm Brochure | Page 8  Firm Brochure would otherwise have been the case had the investor not borrowed to make the investments, and (iii) losses due to premature liquidations of investment positions to meet margin calls. Short sales can substantially increase the impact of adverse price movements on an investor’s portfolio. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, which could result in a theoretically unlimited loss. Further, there can be no assurance that securities necessary to cover a short position will be readily available for purchase, which could result in further losses. Some of MIM’s clients use the assets in their accounts as collateral for non-purpose loans/pledged asset lines of credit. MIM informs clients of the risks presented by doing this, one of which is collateral calls if there is a decline in the market value of the assets. MIM does not extend loans to clients. A private fund is an investment vehicle that pools capital from a number of investors and invests in real estate, securities, private operating companies and other instruments. In almost all cases, a private fund is a private investment vehicle that is typically not registered under federal or state securities laws. So that private funds do not have to register under these laws, issuers make the funds available only to certain sophisticated or accredited investors. They cannot be offered or sold to the general public. Private funds are generally smaller than mutual funds because they are often limited to a small number of investors. Many but not all private funds use leverage as part of their investment strategies. Private fund management fees often include a base management fee along with a performance fee component. In many cases, the funds’ managers become “partners” with their clients by making personal investments of their own assets in the fund. There are other risks associated with private funds which are typically described in the offering and other documents. General Risk of Owning Securities The prices of securities held in client accounts and the income they generate can decline in response to certain events taking place around the world. These include events directly involving the issuers of securities held in a client’s account or which are assets of mutual funds or ETFs in a client’s account, conditions affecting the general economy, and overall market changes. Other contributing factors include local, regional, or global political, social or economic instability and governmental or governmental agency responses to economic conditions. Finally, currency, interest rate, and commodity price fluctuations will also affect security prices and income. Pandemics and Other Public Health Crises Pandemics and other health crises, such as outbreaks of infectious diseases like severe acute respiratory syndrome, avian flu, H1N1/09 flu and COVID-19 or any other serious public health concern, together with any resulting restrictions on travel or quarantines imposed, could have a negative impact on the economy, and business activity in any of the areas in which client investments are located. Such disruptions, or the fear of disruption, could have a significant and adverse impact on the securities markets, lead to increased short-term market volatility or a significant market downturn, and can have adverse long-term effects on world economies and markets generally. Firm Brochure | Page 9  Firm Brochure Cybersecurity Risk MIM has established a Business Continuity Plan, Information Security Policy and a Network Security Policy which are collectively designed to prevent cybersecurity risks. Nevertheless, there are limitations to the efficacy of such plans including the possibility that certain risks have not been identified. Investment advisers and their service providers are susceptible to operational and information security risks resulting from cyber attacks. Cyber attacks include, among other behaviors, stealing or corrupting data maintained online or digitally (including, for example through cyber attacks known as “phishing” and “spearphishing”), denial-of-service attacks on websites, the unauthorized release of confidential information and causing operational disruptions. Cyber attacks can interfere with the processing of transactions, cause the release of private information or confidential information of the firm or clients, cause reputational damage to the firm, and subject the firm to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, and/or additional compliance costs. Disciplinary Information There are no material legal or disciplinary actions, pending or current, against MIM or any of its management persons. Other Financial Industry Activities and Affiliations Neither MIM nor any of its management persons are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither MIM nor any of its management persons are registered or have an application pending to register as a futures commission merchant, commodity pool operator, commodity trading advisor or an associated person of any of the foregoing entities. Except as indicated in the next sentence, MIM has no relationship or arrangement that is material to its advisory business or to its clients with any related party. MIM, or entities it controls, serve as the general partner, manager and investment adviser to Private Funds formed for investment purposes, and its personnel spend as much time as deemed necessary on activities related to managing such Private Funds. See “Performance-Based Fees & Other Compensation” above for details about the compensation MIM receives from Private Funds. MIM receives no compensation from any other investment advisor that it recommends or selects for its clients. While MIM is primarily focused on its investment advisory activities, MIM is a licensed insurance agency in Pennsylvania (license number 927121). Insurance contracts are utilized as a risk management tool in certain family situations. An employee of MIM is licensed as an insurance broker. As a licensed insurance agency, MIM can receive commissions on the sale of insurance products purchased by clients through MIM’s advisor who is a licensed insurance broker (see “Fees and Firm Brochure | Page 10  Firm Brochure Compensation” above for details about the compensation MIM receives from insurance recommendations. MIM’s licensed insurance broker can offer specialized insurance needs analysis and policies in the areas of life insurance, annuities and long-term care insurance planning. MIM could also look to the services of other unaffiliated insurance brokers to conduct reviews and make recommendations to its clients. Insurance services could be provided by either an affiliated or unaffiliated insurance broker. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Except for the general partner or managing member interest in investment entities created by MIM for its clients to invest in, MIM does not buy or sell securities for its own account. However, the employees of MIM are permitted to do so, subject to policies established by MIM. These policies are embedded in the Code of Ethics adopted by MIM pursuant to SEC Rule 204A-1. The Code of Ethics requires all employees of MIM, other than clerical and administrative employees or employees that do not have knowledge of the day-to-day investment activity occurring in clients' accounts, to report all brokerage accounts maintained by them to MIM’s Chief Compliance Officer, to provide him or her on a quarterly basis with records of all trading that occurs in those accounts, and to authorize him or her to obtain periodic statements from each brokerage at which such accounts are maintained and statements showing account holdings on an annual basis. Subject to the limitations discussed below, MIM employees are permitted to hold or trade in the same securities as clients. Employees are prohibited from participating in any transaction which might reasonably be anticipated to adversely affect the market price for a security held in a client account or Private Fund or which is effected in order to benefit from market reaction to transactions in a client account or Private Fund. To ensure that this prohibition is not violated, the aforementioned brokerage records (other than those of the Chief Compliance Officer) are reviewed quarterly by MIM’s Chief Compliance Officer. The brokerage records of the Chief Compliance Officer are reviewed quarterly by MIM’s General Partner or his designee. In addition, the Chief Compliance Officer has established and maintains a list of securities for which employees subject to the policy must obtain written pre-approval before buying or selling such securities (the “Pre-Clearance List”). The Pre-Clearance list includes securities managed by the Firm which might be subject to significant price changes due to trading by the Firm on behalf of its clients and securities in which Firm employees could have material non-public information, such as when a client serves on the board of a public corporation. Employees subject to the policy must also obtain written pre-approval prior to entering into an order for purchase or sale of any initial public offering or any limited offering. MIM and its related persons (i.e., its officers, general partner, non-clerical employees and entities controlled by MIM) are permitted to invest in Private Funds. MIM or its related persons will receive proportional returns associated with investments in Private Funds. In addition, MIM generally receives management and performance-based fees from Private Funds. Management and performance-based fees are typically waived for MIM’s related persons and are not imposed on the general partner of private funds. Firm Brochure | Page 11  Firm Brochure MIM does not exercise its discretionary authority over client accounts to invest those accounts in any Private Fund and will disclose to its clients the involvement of MIM or a related person as a principal, investment adviser or investor in any Private Fund which it recommends to such clients. MIM's Code of Ethics will be provided to prospective or current clients upon request. Brokerage Practices Brokers are selected based on cost, execution, research quality and general service capabilities. MIM has not engaged in any "soft dollar" transactions that might result in its paying commissions higher than those obtainable from other brokers in exchange for products or services and does not plan to do so in the future. MIM does effect transactions for clients with broker-dealers who incidentally provide MIM with research or other related products and services. Such research or other products and services are a benefit to MIM in that it does not have to perform the detailed research using MIM personnel. MIM does not “pay-up” for any of the research or services, nor does it have any obligation for execution. MIM pays competitive commission rates, as applicable, to all of the broker-dealers with whom it trades and regularly evaluates the quality of executions being received. Trades are generally directed to the broker that will execute them at the lowest trading cost to the client. However, trades may be directed to brokers with higher commissions if better trading execution or research quality warrants the higher total trading cost to the client. Most client accounts do not have high trading volumes and therefore are not materially impacted by trading costs. MIM does not engage in principal, agency or cross-agency transactions. MIM commonly directs that a trade be executed by a broker-dealer other than the client’s custodian, a practice referred to as trading away. MIM trades away with respect to any custodian that does not have trade execution capabilities, to obtain a lower commission than that charged by the custodian broker or to allow efficient blocking of trades for all our clients at different custodians. Some custodians charge a fee for allowing MIM to trade away. MIM believes that trading away helps to achieve best execution because it helps to minimize the risk of market movement in pricing, achieves competitive pricing, accesses additional liquidity sources, makes use of more sophisticated trading algorithms and ensures that participating clients receive the same execution price. MIM does not consider, in selecting or recommending broker-dealers, whether MIM has received any client referrals from that broker-dealer. MIM does not permit a client to choose a specific broker for account trades. Clients may designate or directly engage a custodian. To the extent that a client specifies a particular custodian, their brokerage options could be limited. MIM maintains the following policy on bunching of orders and allocation of trades (block trades). Where practicable, block or bunched trades will be pursued by MIM in situations where the decision has been made to purchase or sell an exchange-traded security for more than one client through one broker. Block trades are used in this situation to assure that all clients trading a particular security are treated fairly by Firm Brochure | Page 12  Firm Brochure receiving the same execution price per share for that security. All allocations of the securities bought or sold pursuant to block trades, and the attendant costs, will be made as follows: 2) 1) Prior to any block trade, the target allocation of each client will be determined. Such allocation will be made at the discretion of the Portfolio Management Committee based upon considerations such as the relationship between each client's target allocations and actual allocations in the security or asset class with respect to which the trade is to occur, each client's tax situation (e.g., will trade cause short- term gain, are there offsetting losses, etc.), and each client's investment objective, risk tolerance or other client-specific issues. If less than the total number of securities desired is purchased or sold, all allocations of securities traded will be made to the client accounts in proportion to their respective target allocations. This policy will apply to all equity "IPO" transactions as well as more routine transactions. 3) Client accounts participating in a block trade will receive the same average execution price per share or bond for all transactions effected in the execution of such trade. 4) All other transaction costs (other than custodian-imposed account specific fees) will be shared on a pro rata basis. 5) All trade allocations to client accounts will be made as soon as practicable following a block trade, unless circumstances intervene that render that unfeasible. 6) Records will be kept of all block trades. Review of Accounts Each client account is reviewed by a Portfolio Management Committee member on at least a quarterly basis. The focus of such reviews is asset allocation in terms of the client’s investment objectives. Changes in clients’ personal situations are discussed in the daily Portfolio Management Committee meetings to determine whether any client’s asset allocation should be modified. During the biweekly telephone calls with the Investment Strategy Committee, the Portfolio Management Committee discusses the economic and market conditions as well as high-level recommendations on the positioning of investment portfolios. Additional calls may be occasioned by geopolitical or market conditions. The Portfolio Management Committee members are listed among MIM’s key investment professionals (see Brochure Supplement). Reports are issued to clients at least quarterly and contain a listing of investment positions, investment purchases and sales, deposits, disbursements (including MIM fees) and performance data. Retirement plans for which MIM provides consulting services are reviewed on a quarterly basis or in the interim should the client inform MIM of a change in circumstances regarding the needs of the plan. Client Referrals and Other Compensation MIM has no arrangements whereby it receives any economic benefit from anyone who is not a client for providing investment advice or other advisory services to its clients. MIM currently does not directly or indirectly compensate any third party for referrals of clients to MIM. If MIM changes such policy, any third-party compensation will be in accordance with the requirements of Firm Brochure | Page 13  Firm Brochure Rule 206(4)-1 of the Investment Advisers Act of 1940 and any corresponding state securities law. The third party will disclose at the time of the solicitation whether they are or are not a current client of MIM, the nature and amount of any cash or non-cash compensation from MIM for the referral, and a statement that the receipt of compensation for the referral creates a conflict of interest. All members of MIM’s Investment Strategy Committee have an equity interest in MIM. The members of the Investment Strategy Committee receive no compensation for client referrals. Custody All client securities and cash are custodied with a qualified custodian with the exception of stock certificates of private entities held by Private Funds as allowed by SEC guidance. MIM receives no compensation or other services from its clients’ custodians. MIM does not permit employees or the firm to accept or maintain custody of client assets other than as identified below. There are specific rules and guidance regarding custody of client assets promulgated by the SEC to protect such assets. The SEC deems that an adviser has custody of client assets if a client has granted the adviser the ability to move money from the client’s account to a third party using a standing letter of authorization or to deduct fees from the client’s account, if the adviser acts as general partner of a pooled investment vehicle, if a client or a third party sends client securities or money directly to the adviser, or if an employee of the adviser acts as a trustee of a client trust. When MIM has custody of client assets in these situations, it complies with the SEC rules and guidance regarding custody. As previously disclosed in the “Fees and Compensation” section of this Brochure, MIM directly debits advisory fees from client accounts as stipulated in the client investment advisory agreements. On at least a quarterly basis, the custodian is required to send to the client a statement for each account showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements against the statements provided by MIM to verify the accuracy of the fee calculation, among other things. Clients should contact MIM directly if they believe that there is an error in their statement. Investment Discretion When a client engages MIM to provide discretionary asset management services, trades in the client’s account will be placed without contacting the client. MIM’s discretionary authority includes the ability to do the following without contacting the client: • Determine the security to buy or sell; • Determine the amount of the security to buy or sell; • Determine the broker to be used; and/or • To make trades. Firm Brochure | Page 14  Firm Brochure Clients give MIM discretionary authority when they sign an investment advisory agreement with MIM and they have the ability to limit this authority by giving MIM written instructions. Clients may also change/amend such limitations by once again providing MIM with written instructions. Voting Client Securities In general, MIM does not exercise proxy voting authority for client securities held in SMAs. Each client can choose to vote proxies on its own behalf in which case MIM will direct the custodian to send all proxies to the client for the securities held in its account. This policy is disclosed to each client in its Investment Advisory Agreement. However, when MIM serves as an investment adviser to a Private Fund where it controls the investment vehicle (e.g., an investment partnership where MIM is the general partner), MIM does vote proxies on behalf of the Private Fund through a third-party proxy voting service. In this instance, MIM will instruct the third-party proxy voting service to follow the procedures set forth in its Proxy Voting Procedures when exercising its voting authority. Clients invested in these Private Funds will be provided with a copy of the Proxy Voting Procedures upon request and may contact MIM for information about how MIM voted their securities. Financial Information MIM does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients and has not been subject to a bankruptcy petition at any time. Brochure Supplement This brochure supplement provides information about Elwyn Evans III, Edward A. Glickman, Daniel J. Harnish, Timothy Letter, H. Scott Miller, Henry S. Miller, Jr., Clayton P. Parrett, and Matthew J. Ryan that supplements the Miller Investment Management, LP brochure. The people listed are members of one or more focused investment teams that make investment decisions and/or communicates with clients regarding investment advice within that team’s area of expertise as noted under each individual below. The teams include an owner of the firm and other investment professionals. The Portfolio Management Committee usually meets weekly to discuss and review portfolio investments, asset allocation and strategy. Firm Brochure | Page 15  Firm Brochure Investment Team Scope and Focus Investment Team Members Investment Management (Portfolio Management Committee) Daniel Harnish, Timothy Letter, H. Scott Miller, Henry S. Miller, Jr., Clayton P. Parrett, Private Equity H. Scott Miller, Henry S. Miller, Jr., Clayton P. Parrett Real Estate Edward G. Glickman, H. Scott Miller, Matthew J. Ryan Elwyn Evans, III, Partner Emeritus, Consultant EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Born 1954 Chartered Financial Analyst (CFA)* (see Notes) BSCE, Tufts University (1976); MCE, University of Delaware (1980) Miller Investment Management, LP (FKA Strategic Capital Advisors, L.P.), 1999 to 2021 Partner; 2022 to present Partner Emeritus and consultant. DISCIPLINARY INFORMATION There have been no material disciplinary actions** taken against Elwyn Evans, III (see Notes). OTHER BUSINESS ACTIVITIES Elwyn Evans, III is not actively engaged in any investment-related business or occupation other than that of MIM. ADDITIONAL COMPENSATION Elwyn Evans, III has not received any economic benefit from a person who is not a client for providing advisory services. SUPERVISION Elwyn Evans, III is part of the team that communicates with investment management clients. H. Scott Miller supervises Elwyn Evans, III. To the extent required by MIM’s Code of Ethics, Christine Dostillio, Chief Compliance Officer, supervises all compliance activities of the firm. H. Scott Miller or Christine Dostillio can be reached at the phone number listed on the cover page. Firm Brochure | Page 16  Firm Brochure Edward A. Glickman EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Born 1957 BAS, University of Pennsylvania (1978), BS in Economics Wharton School University of Pennsylvania (1978), MBA Harvard Business School (1981) Miller Investment Management, LP, 2015 to present, 2019-present Registered Representative BA Securities, LLC, 2014-2017 Hentschel & Co., LLC, 2014 to 2017 SDDCO Brokerage Advisors LLC DISCIPLINARY INFORMATION There have been no material disciplinary actions** taken against Edward A. Glickman (see Notes). OTHER BUSINESS ACTIVITIES Executive Director of AIP Asset Management, Consultant at Associated Real Estate Consultants, LLC, advisory roles with various organizations. Registered representative of BA Securities LLC. ADDITIONAL COMPENSATION Edward A. Glickman receives economic benefit from parties who are not MIM clients for providing real estate and corporate advisory services. Edward A. Glickman receives compensation from AIP Asset Management, BA Securities LLC and Associated Real Estate Consultants, LLC. SUPERVISION Edward A. Glickman is part of the team that makes investment decisions and communicates with clients regarding real estate. H. Scott Miller supervises Edward A. Glickman, including the investment advice provided to clients. To the extent required by MIM’s Code of Ethics, Christine Dostillio, Chief Compliance Officer, supervises all compliance activities of the firm. H. Scott Miller or Christine Dostillio can be reached at the phone number listed on the cover page. Daniel J. Harnish EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Born 1992 Chartered Financial Analyst (CFA)* (see Notes) BA, Dartmouth College (2014) Miller Investment Management, LP, 2014 to present. DISCIPLINARY INFORMATION There have been no material disciplinary actions** taken against Daniel J. Harnish (see Notes). OTHER BUSINESS ACTIVITIES Daniel J. Harnish is not actively engaged in any investment-related business or occupation other than that of MIM and its affiliates. Firm Brochure | Page 17  Firm Brochure ADDITIONAL COMPENSATION Daniel J. Harnish has not received any economic benefit from a person who is not a client for providing advisory services. SUPERVISION Daniel J. Harnish is part of the team that makes investment decisions and communicates with clients regarding investment management. H. Scott Miller supervises Daniel J. Harnish, including the investment advice provided to clients. To the extent required by MIM’s Code of Ethics, Christine Dostillio, Chief Compliance Officer, supervises all compliance activities of the firm. H. Scott Miller or Christine Dostillio can be reached at the phone number listed on the cover page. Timothy Letter EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Born 1967 BS, Lynn University (1989) Miller Investment Management, LP, 2018 to present; Prudential Financial 2007 to 2018; MFS Investment Management, 2001-2007. DISCIPLINARY INFORMATION There have been no material disciplinary actions** taken against Timothy Letter (see Notes). OTHER BUSINESS ACTIVITIES Timothy Letter is a licensed insurance agent and may receive separate, yet customary, commission payments for the sale of insurance products. This presents a conflict of interest in that there is a financial incentive to recommend insurance products to clients as part of the advisory services. Clients are under no obligation to purchase insurance products recommended by him or to purchase the products through him. ADDITIONAL COMPENSATION Timothy Letter may receive additional compensation in the form of revenue sharing for referral of new clients to MIM. SUPERVISION Timothy Letter is part of the team that makes investment decisions and communicates with clients regarding investment management. H. Scott Miller supervises Timothy Letter, including the investment advice provided to clients. To the extent required by MIM’s Code of Ethics, Christine Dostillio, Chief Compliance Officer, supervises all compliance activities of the firm. H. Scott Miller or Christine Dostillio can be reached at the phone number listed on the cover page. Firm Brochure | Page 18  Firm Brochure H. Scott Miller EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE President and 100% Shareholder of the corporation which is the sole member of the General Partner of MIM Born 1949 Chartered Financial Analyst (CFA)* (see Notes) BA, Williams College (1971); MBA, University of Pennsylvania (1977) Miller Investment Management, LP (FKA Strategic Capital Advisors, L.P.), 1998 to present. DISCIPLINARY INFORMATION There have been no material disciplinary actions** taken against H. Scott Miller (see Notes). OTHER BUSINESS ACTIVITIES H. Scott Miller is not actively engaged in any investment-related business or occupation other than that of MIM and its affiliates. ADDITIONAL COMPENSATION H. Scott Miller has not received any economic benefit from a person who is not a client for providing advisory services. SUPERVISION H. Scott Miller is part of the teams that make investment decisions and communicates with clients related to investment management, private equity and real estate. To the extent required by MIM’s Code of Ethics, Christine Dostillio, Chief Compliance Officer, supervises all compliance activities of the firm. Christine Dostillio can be reached at the phone number listed on the cover page. Henry S. Miller, Jr. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Born 1972 BA, Williams College (1994); MFA, University of Southern California (1998) Miller Investment Management, LP, 2009 to present. DISCIPLINARY INFORMATION There have been no material disciplinary actions** taken against Henry S. Miller (see Notes). OTHER BUSINESS ACTIVITIES Henry S. Miller is not actively engaged in any investment-related business or occupation other than that of MIM and its affiliates. Firm Brochure | Page 19  Firm Brochure ADDITIONAL COMPENSATION Henry S. Miller has not received any economic benefit from a person who is not a client for providing advisory services. SUPERVISION Henry S. Miller is part of the teams that make investment decisions and communicates with clients regarding investment management and private equity. H. Scott Miller supervises Henry S. Miller Jr., including the investment advice provided to clients. To the extent required by MIM’s Code of Ethics, Christine Dostillio, Chief Compliance Officer, supervises all compliance activities of the firm. H. Scott Miller or Christine Dostillio can be reached at the phone number listed on the cover page. Clayton P. Parrett EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Born 1993 BS, Drexel University (2014) Miller Investment Management, LP, 2014 to present DISCIPLINARY INFORMATION There have been no material disciplinary actions** taken against Clayton P. Parrett (see Notes). OTHER BUSINESS ACTIVITIES Clayton P. Parrett is not actively engaged in any investment-related business or occupation other than that of MIM and its affiliates. ADDITIONAL COMPENSATION Clayton P. Parrett has not received any economic benefit from a person who is not a client for providing advisory services. SUPERVISION Clayton P. Parrett is part of the teams that make investment decisions and communicates with clients regarding private equity and investment management. H. Scott Miller supervises Clayton P. Parrett, including the investment advice provided to clients. To the extent required by MIM’s Code of Ethics, Christine Dostillio, Chief Compliance Officer, supervises all compliance activities of the firm. H. Scott Miller or Christine Dostillio can be reached at the phone number listed on the cover page. Matthew J. Ryan EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Born 1992 BS, Drexel University (2014) Miller Investment Management, LP, 2016 to present DISCIPLINARY INFORMATION There have been no material disciplinary actions** taken against Matthew J. Ryan (see Notes). Firm Brochure | Page 20  Firm Brochure OTHER BUSINESS ACTIVITIES Matthew J. Ryan is not actively engaged in any investment-related business or occupation other than that of MIM and its affiliates. ADDITIONAL COMPENSATION Matthew J. Ryan has not received any economic benefit from a person who is not a client for providing advisory services. SUPERVISION Matthew J. Ryan is part of the team that makes investment decisions and communicates with clients regarding real estate. H. Scott Miller supervises Matthew J. Ryan, including the investment advice provided to clients. To the extent required by MIM’s Code of Ethics, Christine Dostillio, Chief Compliance Officer, supervises all compliance activities of the firm. H. Scott Miller or Christine Dostillio can be reached at the phone number listed on the cover page. Firm Brochure | Page 21  Firm Brochure Notes * The Chartered Financial Analyst (CFA) charter is awarded by CFA Institute. To earn the CFA charter, one must pass three sequential, six-hour examinations, have at least four years of professional investment experience, become a member of CFA Institute, and commit to abide by, and annually reaffirm, one’s adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. ** Below is a list of specific legal and disciplinary events presumed to be material by the SEC. A. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in which the supervised person 1. 2. 3. 4. was convicted of, or pled guilty or nolo contendere (“no contest”) to (a) any felony; (b) a misdemeanor that involved investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; was found to have been involved in a violation of an investment-related statute or regulation; or was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, the supervised person from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order. B. An administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which the supervised person 1. 2. was found to have caused an investment-related business to lose its authorization to do business; or was found to have been involved in a violation of an investment-related statute or regulation and was the subject of an order by the agency or authority a) b) denying, suspending, or revoking the authorization of the supervised person to act in an investment-related business; barring or suspending the supervised person's association with an investment-related business; otherwise significantly limiting the supervised person's investment-related activities; or imposing a civil money penalty of more than $2,500 on the supervised person. c) d) C. A self-regulatory organization (SRO) proceeding in which the supervised person 1. 2. was found to have caused an investment-related business to lose its authorization to do business; or was found to have been involved in a violation of the SRO’s rules and was: (i) barred or suspended from membership or from association with other members, or was expelled from membership; (ii) otherwise significantly limited from investment-related activities; or (iii) fined more than $2,500. D. Any other proceeding in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. In addition, no supervised person has resigned in anticipation of such a proceeding. Firm Brochure | Page 22