GUARDIAN INVESTMENT MANAGEMENT

GUARDIAN INVESTMENT MANAGEMENT, LLC FORM ADV PART2A March 5, 2026 1120 Mar West St., Suite D Tiburon, CA 94920 415-765-6860 www.guardinv.com This Brochure provides information about the qualifications and business practices of Guardian Investments. If you have any questions about the contents of this Brochure, please contact our Chief Compliance Officer, Robert M. Tomasello using the information above. The information in this Brochure has not been approved by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Although all of our Partners and key employees have advanced degrees and/or professional designations. Guardian's registration as an investment adviser does not imply any specific level of skill or training. More information about Guardian Investments can be found on the SEC’s website at www.advisorinfo.sec.gov. There has been no material change in our business since our last ADV filing other than an annual updating of the Firm’s assets under management. DISCLOSURE STATEMENT The Securities and Exchange Commission requires that all registered investment advisors provide certain information to all existing and potential clients. This statement conforms to those requirements. Table of Contents Advisory Business - Item 4 Page 2 Fees and Compensation - Item 5 Page 3 Performance Based Fees and Side by Side Management - Item 6 Page 4 Types of Clients - Item 7 Page 4  Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 Page 4 Disciplinary Information - Item 9 Page 5 Other Financial Industry Activities or Affiliations - Item 10 Page 6 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 Page 6 Brokerage Practices - Item 12 Page 7 Review of Accounts - Item 13 Page 7 Client Referrals and Other Compensation - Item 14 Page 8 Custody - Item 15 Page 8 Investment Discretion - Item 16 Page 8 Voting Client Securities - Item 17 Page 8 Financial Information - Item 18 Page 8 ADV Part 2B, Biographical Information Page 9 Advisory Business/ Overview Robert M. Tomasello and Donald L. Hansen formed Guardian Investment Management (GIM) in 1976 as a partnership. In January 2015, Guardian reorganized as a Limited Liability Company under California law. We have continuously offered investment advice to our clients since 1976. Investment management is the only business and exclusive source of income for Guardian. We do not offer or sell any other type of service. We do not share in any compensation with respect to security trade commissions. We are not registered as a broker nor are we affiliated with any broker, dealer, Investment Company or other investment adviser. We do not buy or sell securities as principal with respect to security trades. Guardian Investments is owned and operated by the active Partners listed at the end of this document. As a Fiduciary, we offer independent and unbiased investment management. Our primary focus is on preservation of capital and protection from inflation. Our business consists of managing security accounts, each of which uses as custodian, a bank, or broker selected by the client. We hold a limited power of attorney that authorizes us to buy or sell securities. Although we do not consult with clients prior to individual security purchases and sales, occasional consultations are held to discuss general matters such as how the account managed by Guardian Investments 2  relates to the client's other assets and requirements. Some clients impose restrictions on investment in certain securities or types of securities. Client portfolios are invested in stocks, taxable and tax-exempt bonds, and short-term instruments such as Treasury bills and money market funds. On occasion, we may invest in mutual funds, Exchange Traded Funds and other similar co-mingled investment products, particularly for smaller accounts managed as a courtesy for existing clients. A separate account is maintained for each client. To the extent any client is a retirement plan or other employee benefit plan subject to the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), and depending upon the investment management services provided by us, the Firm may be considered a "fiduciary" under ERISA. Guardian operates under an Investment Management Agreement with each client. For new clients, following the initial execution of this agreement, it may be terminated at any time by either party on five calendar days' written notice delivered to the other without payment of penalty and without liability of either party to the other. For existing clients, this agreement can be terminated at any time. As of December 31, 2025 our total assets under management was $310,319,537. Included in this total is $263,725,237 of fully discretionary assets under management. We furnish quarterly portfolio valuations to our clients. These reviews include the current value and cost basis of each security, and the current value and allocation of the total portfolio. In addition, the custodians also issue monthly statements and copies of all confirmations to the client. Fees and Compensation Individual Clients: Institutional Accounts: 1% on the first $2,000,000 $1-10 million 7.5/10ths of 1 % 7.5/10ths of 1% above $2,000,000 > $10 million 6/10ths of 1% Fees are negotiable, depending on the equity/bond allocation in the portfolio. We compute the fees based on the portfolio valuation as of the end of each quarter, and the fees are for the following three months, so they are paid in advance. If the investment management contract is canceled during the quarter, the client will receive a refund for the pro-rated number of days remaining during the quarter. Most of our clients’ quarterly fees are deducted from the custodian account. A few clients are billed directly per their request. Clients who have chosen to have a bank custodian may also pay a custodian fee. Our fees are based only on the assets under management. The minimum account size that we accept is $1,000,000, although smaller accounts are accepted on occasion. We do not use performance based fees. 3  In addition to investment management fees, clients will pay commissions to their broker / custodian upon the purchase or sale of an investment (see Broker Practices on page 6). In most cases, investment management fees are deducted directly from clients' accounts by Guardian Investment and clients receive a "notification only" bill. We believe these fees are similar to those charged by many other investment counseling firms for similar services; however, comparable service may be available from other sources for lower fees. Performance Based Fees and Side-by-Side Management Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Guardian does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk than is suitable for the client. Types of Clients Although most of our clients are individuals, some clients are trusts, charitable foundations, retirement plans, estates, and corporations. Minimum dollar valuation for starting an account is $1,000,000. Under special circumstances, smaller accounts are occasionally accepted. Methods of Analysis, Investment Strategies and Risk of Loss We are long-term investors – not speculators – and our investment philosophy is conservative in nature. However, clients should recognize that investing in any type of stock or bond security poses some level of risk. In our initial discussion with potential clients we will quantify and discuss the volatility inherent in investing in more detail. Individual securities in specific and, more broadly, economic, environmental, political and market developments can result in the value of investments declining. There is no guarantee of investment return and past performance is no guarantee of future success. Our investment approach consists of fundamental analysis, as opposed to technical or quantitative strategies. We study company financial statements and reports, industry trends and conditions, and general business conditions. Principal sources of information are (1) the company's annual report, prospectus, Form 10-K and press releases, (2) general business periodicals, newspapers and the internet, and (3) analyst reports. Core Investment Strategy Guardian’s Core strategy for stock selection focuses on large, multi-national companies domiciled in a G7 nation and traded on U.S. based stock exchanges either as a domestic stock listing or as a depository receipt (ADR or ADS.) Guardian seeks to identify companies that use shareholder capital in a disciplined way, that have strong financial strength and attractive valuations in the market. We screen from the 2,000 largest companies traded on domestic exchanges and then 4  apply both quantitative and qualitative filters to narrow the list to approximately 50 names from which we select the 30 to 35 most attractive holdings to use in client accounts. Client holdings may vary greatly due to a variety of factors including but not limited to legacy positions, unrealized capital gains, and personal preferences in addition to suitability, risk tolerance and other factors. Guardian may use covered call options to help clients diversify out of concentrated positions and/or generate extra yield for those positions. For example, if a client retires from working at a publicly traded company with a large holding in that company’s stock, we can usually use covered calls to earn income on all or a portion of that holding setting strike prices that the client is comfortable selling and diversifying the holding at over time. A small group of clients with greater risk tolerance and knowledge may request covered call options in their taxable account, despite tax efficiency issues. We may hold cash reserves when valuations are high and/or when clients request cash positions. Balanced Strategy Guardian constructs and allocates client portfolios using a combination of stocks and bonds. Typically, we maintain the stock portion of a client's total holdings with a target of 60-70% of the total value of the account, but other targets are occasionally utilized to meet specific client needs, objectives, age, and risk tolerance. A typical clients’ total holdings would include 25 to 35 stocks. The bonds or cash equivalents in a portfolio are intended, in part, to reduce volatility. We select investment grade bonds - U.S. Government issues, municipal bonds, and corporate bonds, although we have not recently invested in municipal bonds given the rate environment. Usually, about 30 to 40 percent of a clients’ combined accounts are invested in bonds or cash equivalents. Assets not invested in stocks or bonds may be invested in cash equivalents such as money market funds and Treasury bills, to maximize short-term returns. We may hold cash reserves when valuations are high and/or when clients request cash positions. Disciplinary Information Guardian Investments hereby certifies that neither the firm nor any Partners or employees of the firm are presently debarred, suspended, proposed for debarment, or denied the ability to actively participate in the investment industry. Guardian Investments, LLC as a firm, and all Partners and employees of the firm, have never been convicted or had a civil judgment rendered against them for any reason, and are not presently indicted for, or otherwise criminally or civilly charged by any governmental entity with commission of any offense. This certification extends for every Principal of Guardian. 5  Other Financial Industry Activities or Affiliations Guardian Investments is an independent investment advisor, unaffiliated with any other financial institution or securities dealer or issuer. We recommend that our clients custody their assets with Charles Schwab & Co., Inc., ("Schwab"), a qualified custodian and SEC registered broker-dealer and member of FINRA and SIPC. Although we recommend that our clients custody their investment accounts at Schwab, we have no affiliation with them, do not supervise their custody or brokerage activities and are not subject to their supervision. Clients are free to choose alternative qualified custodians or banks for their accounts. It is very important to address various areas of potential conflict of interest in the investment management business to reassure our clients. Potential areas to review should include: partners personal trades, use of commissions (soft dollars), use of limited power of attorney, and custody of assets. Transactions for clients always have priority over the personal trades of our principals and associates. Our trades at Schwab are electronically executed on the web, and the commissions are minimal. We do not use commissions to buy brokers’ research. Our limited power of attorney does not allow us to withdraw funds from a client’s account: it only allows us to buy or sell securities. One of the most important protections for our clients is the use of an independent custodian. A custodian is charged with the responsibility of keeping each account separate and only accepting instructions that a client approves. The custodian also issues a monthly statement that shows all of the activity in the account. Our clients should review the monthly statement to ensure that the advisor’s reports are accurate, and that the advisor is adhering to the agreed investment objectives. Although we may refer our clients to other professionals such as attorneys or accountants for estate planning, tax or other matters, neither the Firm nor its partners or employees are affiliated with any law or accountancy firm. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Guardian Investments' Code of Ethics is applicable to all Partners and employees of the Company. Our full Code of Ethics is available upon request. While proper and ethical behavior is expected of every principal and employee in all aspects Guardian’s following Fundamental Standards will serve as a basic guideline for our Firm: 1. Partners and employees will always place the interests of our clients first. 2. Partners and employees will conduct all aspects of their personal business in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility. 3. Partners and employees will not take inappropriate advantage of their positions. 6  Regarding compliance with SEC regulations on insider trading, transactions for clients always have priority over the personal transactions of partners and associates. Personal transactions of partners or associates never operate adversely to clients' interests. Partners and associates occasionally buy or sell securities bought or sold for clients. Partners/associates are required to conduct all aspects of their personal business in such a manner to avoid any actual or potential conflict of interest. Partners/associates are prohibited from placing personal trades for securities when there are open client orders for that security. This effectively means that all trades for partners/associates take place at the end the day after all client trades have been completed. The one exception would be periods when the firm makes a series of transactions in a given security for client accounts over a period of several days. In this case, no personal trades in this security would be allowed until after all client transactions are complete. The company maintains a file (updated quarterly) on all partners' and associates' transactions involving the purchase and sale of equity securities. Brokerage Practices Client accounts are usually held in custody at the major broker Charles Schwab & Co. We do most of our research ourselves and it applies to all of our clients. Occasionally, we receive research pieces from outside brokerage firms. When clients request assets be held at a major brokerage firm of their choice, they are subject to commissions by that brokerage firm. The client negotiates these fees directly with their brokerage firm. Review of Accounts Client accounts are reviewed on at least a quarterly basis and any time there are major cash-flows in or out of an account. Further, major changes in a client’s life (e.g., job change, retirement, death of a spouse or parent) would trigger a review of their accounts. Changes in our view of the long-term view of a given security would also result in a review of client accounts. Client Referrals and Other Compensation We have no referral agreements nor are we compensated by any broker dealers, promoters, or other entities. Custody All of our clients use a custodian bank or a brokerage firm as custodian. We do not serve as Trustee of any client account. We do not have custody of client’s securities or cash assets. Every portfolio is managed separately to meet the specific goals of the individual client. Although most of our clients area individuals or trusts, we also offer advice to retirement accounts, tax free entities and other organizations. Investment Discretion The vast majority of client accounts under our care are fully discretionary – meaning that the client has given Guardian written authorization (in the form of a 7  limited power of attorney) to buy and sell securities on their behalf without additional consultation between Guardian and the client. In very rare circumstances, Guardian consults with clients prior to initiating trades for that client. Voting Client Securities Guardian does not vote proxies or vote on corporate reorganizations for client accounts except when required to by law – usually for retirement accounts covered by ERISA regulation and law. We do provide clients with advice on these matters when solicited. Financial Information We are required in this Item to provide you with certain financial information or disclosures about Guardian’s financial condition. Guardian does not require prepayment of more than $1,200, six or more months in advance. Additionally, Guardian has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has never been the subject of a bankruptcy proceeding. 8  GUARDIAN INVESTMENT MANAGEMENT, LLC FORM ADV PART2B March 2026 1120 Mar West Street, Suite D Tiburon, CA 94920 650-765-6860 www.guardinv.com This Brochure provides information about the qualifications and business backgrounds of the principals and associates of Guardian Investment Management. If you have any questions about the contents of this Brochure, please contact our Chief Compliance Officer, Stephen A. Ethridge using the information above. The information in this Brochure has not been approved by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Although all of our Partners and key employees have advanced degrees and/or professional designations. Guardian's registration as an investment adviser does not imply any specific level of skill or training. More information about Guardian Investments can be found on the SEC’s website at www.advisorinfo.sec.gov. Key employees of Guardian are listed below. Guardian has made a specific effort to build a multi-generational team in order to ensure the continuity of the Firm so that clients will always have a reliable and continuing sources of investment advice. Principals Robert M. Tomasello Bob is a native San Franciscan. After graduating from St. Ignatius College Prep and the University of San Francisco, Bob joined Bank of America as an investment officer. His experience at B of A was invaluable in founding Guardian Investment Management in 1976. Bob brings over 50 years of investing experience to Guardian. Bob’s civic activity includes three years as Chairman of the Board of California Pacific Medical Center’s (CPMC) Foundation and five years as Regional Chairman of Sutter Health. He spends three to four hours per week on this service to the broader San Francisco Bay Community. He was also the past President of the Olympic Club Foundation, past Regent of St. Ignatius College Preparatory, and past Vice President of The Guardsmen. Bob earned an MBA degree from Golden Gate University. Bob is Guardian’s President. Donald L. Hansen Don graduated from the University of Iowa in 1961 and spent 4 years as an officer in the U. S. Navy. After leaving active duty, Don spent 4 years with Dean Witter, before joining Bank of America as an Investment Officer and founder of their Investment Counselling Department. Don brings over 50 years of investment experience to Guardian and is a member of the CFA Institute and the CFA Society of San Francisco. 9  Denise L. Doley Denise joined Donaldson, Lufkin, Jenrette as a Financial Advisor in 2000 after earning her MBA from the Johnson Graduate School of Management at Cornell University. She remained at DLJ and Credit Suisse (acquired DLJ) providing comprehensive wealth management services to individuals, executives, and venture capital firms (and their LPs.) She subsequently worked with both early-stage venture companies and within the hotel and lodging industry, valuing assets and investments. She joined Guardian in 2014. Denise earned her Bachelor of Arts in Business Economics from the University of California, Santa Barbara and studied internationally at both Universite d’Aix Marseille and the Stockholm School of Economics. 10