JAMES HAMBRO & PARTNERS LLP

F O R M A D V P A R T 2 A , F I R M B R O C H U R E 1 © 2025 James Hambro & Partners. All rights reserved.  F O R M A D V P A R T 2 A , F I R M B R O C H U R E 45 Pall Mall London SW1Y 5JG United Kingdom Tel: + 44 (0) 20 3817 3500 Fax: + 44 (0) 20 3817 3414 Website: www.jameshambro.com CRD Number 286283 SEC File Number 801-110820 10th November 2025 This Brochure provides information about our qualifications and business practices. If you have questions about its contents, contact us at +44 (0)20 3817 3500 or compliance@jameshambro.com. The information in this Brochure has not been approved or verified by the U.S. Securities and Exchange Commission or by any non-U.S. or U.S. state securities authority. Additional information about us is available on the SEC’s website at www.adviserinfo.sec.gov. The disclosures in our Brochure are solely for U.S. resident clients. 2 © 2025 James Hambro & Partners. All rights reserved.  ITEM 2. MATERIAL CHANGES This is our Brochure on Form ADV Part 1. This is an Other than Annual update to provide information about changes in our equity ownership. On November 10th 2025, certain members of the partnership sold equity to an external investor, MCB Eider Holdings Limited (“MCB”). MCB does not hold a controlling interest. Our ADV Part 1 has been updated. There has been no change to the management, nature or structure of the business as a result of this transaction. The information in this document has been updated for equity ownership changes only. All other information will be updated at the annual refiling. We will send you a copy of our Brochure, without charge, if you call us at +44 (0) 20 3817 3500 or e-mail us at clientservices@jameshambro.com. You can find more information about us via the SEC’s web site, www.adviserinfo.sec.gov. 3 © 2025 James Hambro & Partners. All rights reserved.  ITEM 3. TABLE OF CONTENTS ITEM 2. MATERIAL CHANGES ........................................................................................................................ 3 ITEM 3. TABLE OF CONTENTS ....................................................................................................................... 4 ITEM 4. ADVISORY BUSINESS ........................................................................................................................ 5 ITEM 5. FEES AND COMPENSATION .............................................................................................................. 6 ITEM 6. PERFORMANCE FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................ 6 ITEM 7. TYPES OF CLIENTS ............................................................................................................................ 7 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .......................................... 7 ITEM 9. DISCIPLINARY INFORMATION ......................................................................................................... 16 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ...................................................... 16 ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ...................................................................................................................................................... 17 ITEM 12. BROKERAGE ................................................................................................................................. 18 ITEM 13. REVIEW OF ACCOUNTS ................................................................................................................ 21 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION ....................................................................... 21 ITEM 15. CUSTODY ...................................................................................................................................... 21 ITEM 16. INVESTMENT DISCRETION............................................................................................................ 22 ITEM 17. VOTING CLIENT SECURITIES ......................................................................................................... 22 ITEM 19. REQUIREMENTS FOR STATE-REGISTERED ADVISERS..................................................................... 22 4 © 2025 James Hambro & Partners. All rights reserved.  ITEM 4. ADVISORY BUSINESS James Hambro & Partners LLP (“JH&P”, “our” or “we”) is a UK-based investment manager. We were established in 2009. Our principal office is based in London. We have 166 staff, including 28 persons who are employees of James Hambro & Co Ltd. (“JH&Co”), a company for which we are the 100% owner, and who are associated persons of ours. JH&P is a partnership which is majority owned (c81%) by members who actively contribute to the business. This includes indirect ownership through shares in JH&P Holdings which owns c15% of the partnership. We identify our related persons in our Form ADV Part 1. Our structure brings both freedom and responsibility with partners having a strong motivation to work together to contribute a superior service and investment success for clients. For our non-US clients, we provide discretionary and non-discretionary (Advisory and Execution only) investment management across a range of equity strategies, as noted below. We offer our services through separately managed accounts, listed funds and pooled investment vehicles (“private funds”), for individuals, families, trusts and charities in the mandates described in Item 8. For our U.S. clients (defined as those clients who have signed our U.S terms of business), we provide discretionary investment management in separately managed accounts. For the purposes of this document “clients” means U.S. clients. We combine integrity and expertise with an investment resource which is firmly focused on our aim to deliver first class performance. We believe that the combination of a group of attentive and experienced private wealth and charity managers with the resources and skills of an award-winning investment team makes us different. We believe that the following attributes combine to differentiate our offering: • Partnership – Our structure brings both freedom and responsibility with partners having a strong motivation to work together to contribute a superior service and investment success for clients. • Simplicity – We established ourselves from scratch, giving us the opportunity to keep our business uncomplicated with few of the distractions normally associated with more mature businesses, and focused on one clear objective – identifying and meeting the needs of clients. • Resources – Our partners have an average of over 20 years’ experience in financial markets, covering investment management and financial planning. • Performance – Our sole focus to deliver the long-term investment outcomes that our clients require. Since inception, our portfolios have consistently ranked in the top quartile of Asset Risk Consultants peer group of private client fund managers. The investment management services that we provide are dependent on and limited to the client’s investment objectives and restrictions. All clients complete and sign a Client Application Form which, in turn, is a declaration that they accept our Terms and Conditions and agree to our Costs and Charges Disclosure. These legally binding documents comprise the investment management agreement (“IMA”), which governs our relationship and specifies the investment objectives and restrictions. We do not participate in wrap fee programmes. 5 © 2025 James Hambro & Partners. All rights reserved.  As of 30 April 2025, we manage assets for 6,418 clients in 10,063 accounts. Discretionary assets under management are $8,920,163.46 and non-discretionary assets under management are $.1,643,446,269.761 We may invest clients in funds that we manage; clients are not charged a management fee for the proportion of their portfolio invested in these funds. The disclosures in this Brochure relate solely to our activities for U.S. resident clients (“clients”). ITEM 5. FEES AND COMPENSATION Clients pay a management fee based on a percentage of assets under management (“Fee”), which includes the Research Fee as discussed in Item 12 below. Other costs, such as brokerage and other market charges will be passed on the client. These are presented in our costs and charges disclosure. We do not charge a performance fee. The typical annual investment management fee (our Fee) is based on a tiered scale of 1.0% on the first $5,000,000, 0.8% on the next $5,000,000, and negotiable thereafter. A research fee of up to 0.05% is also charged. Fees are calculated quarterly in arrears on the last day of each quarter. Clients will contract directly with the custodian and we do not receive any fees or retrocession from it. If requested, we can provide an introduction to a custodian. The custodian will value client positions. We also value positions and we reconcile our valuations with those of the custodian. The custodian’s own fees include the fees for holding assets, and may also include settlement charges, interest and dividend collection costs incurred, quarterly statements, valuations and regulatory reporting. We send our clients an invoice for our Fee quarterly, which is based upon our valuations as reconciled with the custodian. Our clients instruct their custodian, acting as their agent, to pay our Fee against the invoice. This arrangement is put in place at the outset. The custodian is also paid in this manner. Alternatively, clients may choose to pay our Fee and the custodian’s fee directly. We do not provide custody or related services to US clients and these and the costs thereof are governed by the clients’ own arrangements. In the case of an investment in funds, clients as investors also bear other fees and expenses, including administration, audit and legal. We do not invest clients in affiliated funds. ITEM 6. PERFORMANCE FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge a performance fee on any managed client assets. 6 1 FX rate of 1.3329 © 2025 James Hambro & Partners. All rights reserved.  ITEM 7. TYPES OF CLIENTS For our U.S. clients, we provide discretionary investment management in separately managed accounts across the mandates as described in Item 8. ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Global equities form the core of our investment approach Global equities provide compelling opportunities for wealth creation over the long-term We look for profitable, growing businesses with durable advantages that allow them to earn high returns on investment for a long period of time. We seek all-weather businesses with the resilience to support continued investment through tough times. This enables a business to adapt and exit a slowdown in a stronger competitive position than they entered it. Combined with a longer-term mindset, we can view these businesses through a different lens to many investors who are increasingly preoccupied with short-term benchmark performance considerations. Balancing equity risk Alongside equities, we invest in a range of diversifying asset classes including government and corporate bonds, infrastructure, absolute return funds and gold. These are intended to reduce the overall portfolio risk and volatility through an investment cycle in two ways. They either offer protection through unstable market periods or diversify the sources of growth and income by being lowly correlated to equity markets. Selective use of external specialists We combine our direct equity investments with specialist strategies that either offer exposure to areas where the long-term structural themes are attractive, but where direct investment is more challenging, or where a more diversified approach is appropriate. Specialist knowledge, language, access or even culture can add hurdles. The managers of these funds can specialise by sector, region, asset class or investment style. We place great importance on liquidity For clarity, we do not invest directly in derivatives or more esoteric holdings. We also do not invest in any lock- up managed funds. THE INVESTMENT PROCESS AND PORTFOLIO CONSTRUCTION We begin with a clear assessment of each client’s investment objectives. This is an essential step which analyses the client’s capacity and tolerance for risk, income requirements and broader investment objectives. Once these are agreed the proposed investment solutions fall broadly into one of the four long-term strategies shown in the chart below. Based on the independent analysis by Bita Risk Consultants Ltd based of market data and asset returns since 1969, we have constructed four differentiated portfolio strategies. These strategies are built on a range of asset allocations designed to meet the differing risk and return objectives of clients. These strategies then provide a framework on which to base the most appropriate approach for each client. 7 © 2025 James Hambro & Partners. All rights reserved.  Taken from a study by BITA Plus Consultants Ltd, commissioned by James Hambro & Partners, September 2011. The table on the following page shows the different outcomes of investing in our four long-term strategies, using neutral strategic weights, from December 1969 to March 2025 We believe this period is representative of the average returns for all the major asset classes over a number of cycles, encapsulating significant market events such as the oil crisis in 1972/1973, the Asian debt crisis of 1997, the dotcom bubble of 2000, the financial crisis of 2008 and COVID-19 of 2020. Return Historic Risk Historic Worst Trough Best 12 Months Best 24 Months Worst 12 Months Worst 24 Months % Positive Months 9.0% 7.3% -16.0% 39.9% 67.2% -13.4% -13.8% 67.3% JH&P Cautious Portfolio JH&P Balanced Portfolio 9.4% 8.9% -25.3% 46.5% 79.9% -18.1% -22.5% 65.5% Steady Growth 9.8% 10.8% -33.7% 53.6% 93.3% -24.3% -30.4% 63.2% JH&P Portfolio JH&P Adventurous Portfolio 10.2% 12.8% -41.7% 59.9% 110.9% -29.8% -38.0% 63.7% The above table derived from a study by Bita Risk Consultants Ltd originally commissioned by JH&P on 06/09/2011. Data covers the period 31.12.69 to 31.03.2025. Historic nominal return and risk are for the total period covered by the Bita Risk Consultants Ltd study. Risk is defined as standard deviation and taken from the returns study undertaken by Bita Risk Consultants Ltd. Worst Trough – the highest percentage fall from a prior peak to the lowest point of retrenchment within the period of the Bita Risk Consultants Ltd study. Past performance is not a reliable indicator of future performance. 8 © 2025 James Hambro & Partners. All rights reserved.  PORTFOLIO CONSTRUCTION IN DETAIL Defining our universe We estimate that there are approximately 3,300 companies in our investable universe (we do not invest in direct equities in emerging markets). However, applying our stringent liquidity requirements that are at the centre of all our investment considerations, lowers this number to c.1,500 companies. Using a third-party analysis tool, we apply rigorous quantitative tests that identify companies that have historically generated high and stable returns and where the prospects for this to continue are high. We avoid highly indebted companies (relative to the cash flows they generate) as this can protect against the loss of capital should our thesis be wrong, or should economic conditions deteriorate. Applying these additional criteria reduces our target list of companies to approximately 600. Focus on quality Empirical evidence shows that companies that can sustain a high return on capital outperform over the business cycle. The evidence also shows that these types of business typically experience a more stable returns profile, higher levels of cash generation and lower indebtedness, which correspondingly leads to less volatile share price movements than the average company. Therefore, if we can identify these businesses, we have the opportunity to own higher quality companies that generate high sustainable returns but with less risk than the average company. We also believe that theshortened investment time-horizons of institutional asset managers can result in markets undervaluing businesses with durable competitive advantages and persistent above-average returns. We look to identify companies that have: • Sustainable growth achieved by selling mission critical services or products that are recurring or predictable in nature • Strong profitability and limited capital intensity leading to high return on capital through the economic cycle • Excellent management whose incentives are aligned with long-term shareholders, preferably through ownership of large stakes in the business themselves. A full stock note is completed on each company which is then reviewed and discussed by the Investment Committee; where possible we meet with the management team before we invest. We are global in our approach, but we believe portfolios should be focused: typically, the equity portion of client portfolios will comprise between 25-35 direct company positions. Third-party funds provide exposure to specialist areas We combine our direct equity investments with specialist funds that can deliver uncorrelated returns relative to the individual companies within portfolios, or exposure to areas where the long-term structural themes are attractive but where direct investment is neither practical nor desirable. This could be a particular sector such as pharmaceuticals, where the economics of successful drug discovery are attractive but the knowledge barrier to understanding and interpreting clinical trial data is high. Similarly, we may use a specialist third-party fund to invest in a region of the world where the growth and demographic outlook is promising but factors such as language, access or even culture add hurdles. We aim to select managers that complement our top-down strategic or thematic views. We analyse factors such as manager history, process, portfolio construction, fund characteristics, style, liquidity, the investment house, ownership structure, manager incentives and fees. We always meet the manager of a pooled vehicle 9 © 2025 James Hambro & Partners. All rights reserved.  before investing and the investment team scores each manager on a number of key metrics. As with direct equities, each pooled vehicle is reviewed and approved by the Investment Committee. Formal reviews of our pooled vehicles are undertaken monthly by the investment team. Fixed income and alternative assets used to balance equity risk Alongside equities, we invest in a range of diversifying asset classes including government and corporate bonds, infrastructure, absolute return funds and gold. These diversifying assets are intended to reduce the overall portfolio risk and volatility through an investment cycle and fall broadly into two groups: • Safe-haven or protective assets that can maintain value through periods of heightened market or geopolitical risk; e.g. gilts, US treasuries, gold. • Growth investments that should contribute to the long-term real return target of the portfolio, but which diversify the overall risk of the portfolio by being lowly correlated to the equity market. In other words, they are capable of growing in periods when equity markets are not. These would include infrastructure, absolute return funds and some asset-backed strategies. Investment team structure We do not operate a separate research team. This means the individuals that manage your assets are directly involved in the analysis and, through the Investment Committee, selection of the investments held on your behalf. This means that portfolio managers are directly responsible and accountable to clients for all investment decisions. From an organisational basis our investment professionals sit on sub-committees, which include fixed interest, direct equities, specialist funds and diversifying strategies. These committees report into the Investment Committee where investment ideas are presented in full and debated by the investment team. Our buy lists are constantly monitored and maintained, and portfolio managers can only allocate within their client portfolios to assets that are on these lists. We do not employ analysts working solely on specific asset classes or sectors, preferring to operate a generalist model. We believe generalists develop a broader understanding of the investment universe and therefore build a level of context that is of higher value to the investment process and portfolios construction. Using specialist analysts can also create conflicts within an organisation, where an analyst may feel compelled to promote investment opportunities that may not provide the best opportunities for clients. RESPONSIBLE INVESTMENT Our business is built around what is best for our clients. Responsible investment is an important part of our investment philosophy as we believe companies that consider the wider impact of their behaviour and operate in a sustainable way are more likely to deliver enduring value for our clients. Our global investment approach embeds environmental, social and governance (ESG) factors into our analysis. Alongside engaged active ownership this can promote sustainable behaviour and a commitment to press for improvements in the wider market. We invest in companies that have consistently delivered attractive and sustained returns to shareholders and offer good opportunities for future growth. However, this growth cannot be at any cost and must be supportive of a move towards a more robust and sustainable economy. It is our view that economic growth pursued without regard for ESG risks will ultimately prove unsustainable 10 © 2025 James Hambro & Partners. All rights reserved.  INTEGRATION OF RESPONSIBLE INVESTMENT JH&P's proprietary 5-Point Sustainability Framework is a materiality-based assessment of the risks and opportunities faced by a business. For each direct company on our Buy List a 5-Point Sustainability Review is produced alongside the Stock Note. The purpose of the review is: 1. To establish conviction around the idea both from a business model proposition but also from the perspective of the company’s culture, purpose, and longer-term attitude to sustainability. The framework gives us deep insight ultimately making us better owners should we invest. 2. To provide a roadmap for our future engagement and voting. Some of our companies will have a higher level of risk than others. Through our Sustainability Reviews, we can build a list of priorities as well as identify common issues across companies for ongoing engagement. Our reviews are first and foremost looking for transparency and acknowledgment. We then assess the strategy of the company to mitigate the risks they face. We also want to see an executive level of engagement and oversight with the requisite governance to ensure compliance. Our sustainability analysis is pragmatic. Although a company may face material risk in relation to our five pillars of focus, they may also be well equipped to address these risks. For example, while a large food manufacturer may have many risks relating to sourcing raw materials, labour conditions and packaging complexity, they are equally best placed given their capital and market position to facilitate change for good. We therefore look at materiality in the context of company action to judge the investment proposition. By working with companies in a collaborative fashion we believe we can be stewards for positive change. A truly sustainable business will be one that has recognised the major long-term threats to its continued success and developed a credible plan to address them. OUR 5-POINT SUSTAINABILITY FRAMEWORK The five pillars that underpin our analysis are influenced by the UN Sustainable Development Goals (SDGs). They capture the major themes we believe are most important to identify companies best placed to benefit from the transition towards a cleaner and more resilient path of economic growth. For each of the five pillars, our primary analyst assesses the materiality of the risks to the investment case (high, medium, low) as well as an assessment of how well the company is addressing the risks and opportunities against several underlying questions DECARBONISATION Climate change is among the most pressing threats facing the world today. We expect companies to understand and quantify their carbon (and greenhouse gas) emissions in all parts of the value chain and have credible plans to reduce this over time. TRANSITION TO A CIRCULAR ECONOMY To reduce the impact of society on the planet, companies must begin to transition to a more sustainable use of the world’s resources and take ownership of the impact of their products from creation to consumption. 11 © 2025 James Hambro & Partners. All rights reserved.  PROTECTION AND RESTORATION OF BIODIVERSITY AND ECOSYSTEMS Companies must address their dependencies upon natural capital and ecosystem services and act to mitigate their impact on the wider environment. Analysis here includes how companies consume raw materials, their use and treatment of water, animals, and their impact on local ecosystems, including air quality. EQUITABLE, HEALTHY AND SAFE SOCIETY Businesses can play a part in creating a fairer society and recognising a purpose beyond pure profit maximisation. We look at sustainability in the context of all stakeholders including any person who is impacted by the activities of the enterprise. A truly sustainable firm is one that enriches its shareholders without exploiting its direct and indirect labour force. STRONG GOVERNANCE AND ACCOUNTABILITY Strong corporate governance is an essential quality for corporate success. Without corporate controls and accountability, we cannot be sure a business is acting in the best interests of its shareholders. CATEGORISING COMPANIES TO PROVIDE A RISK-BASED APPROACH TO ENGAGEMENT Based on what the business does and how they do it, we then categorise each company under three headings: Mitigating, Transitioning, Enabling. This simple risk-based framework has a key influence on the conviction we build on the long-term success of the company and therefore the price we are willing to pay. It also helps inform our overall portfolio construction and drives our engagement priorities and areas of focus; we expect to dedicate more of our engagement activities to companies we classify as Mitigating and Transitioning. Mitigating Companies that offer products and services which are essential to continued societal progression but fall foul in some way to the sustainability goals are classified as Mitigating. To be Mitigating they must have a credible plan for incremental improvement. Mitigating companies carry the highest level of risk and are typically the focus of more of our engagement activity. Transitioning Companies that provide products and platforms on which sustainable development can be advanced are classified as Transitioning. Many companies in this definition are largely neutral to the sustainability debate but they should not materially detract from the five points within our framework. These companies might have a negative environmental impact but the products they produce provide an overwhelmingly positive end market outcome. In these cases, such companies must have credible plans to reduce their own impact. Enabling Companies enabling positive change directly through the sale of their products or services are classified as Enabling. These companies are attractive given regulatory and capital allocation trends. 12 © 2025 James Hambro & Partners. All rights reserved.  STEWARDSHIP AT JH&P We have been signatories to the UK Stewardship Code for the past three years, an achievement we are proud of given our size, and an accolade we believe is testament to the quality and standards we all uphold in providing for our clients. For more information on responsible investment at JH&P, including our analysis, engagement, voting and stewardship across all asset classes, please see our website which houses additional resources. RISKS & CONTROLS Monitoring risk at each stage of the investment process All portfolios are subject to daily monitoring to ensure that they remain consistent with the agreed investment strategy and risk tolerance. Portfolio managers have some discretion to deviate from the agreed framework at the tactical asset allocation level in order to meet the objectives of a client’s portfolios. For a predefined level of risk, all portfolio managers must be within the agreed limits for each asset class. These will be sufficient for the specific circumstances of an individual client to be reflected, but not significant enough for the overall portfolio result to produce an unacceptable dispersion of performance returns for a similar mandate. At an individual security level, the investment team maintains a list of approved investments that have been reviewed in accordance with our investment process to fulfil those mandates. Within discretionary and advised mandates, portfolio managers are not permitted to invest in or advise on investments that are not on the internal approved list. Further limits are placed on maximum holding sizes for individual securities. Our risk framework encompasses both ‘process-based’ (real-time monitoring of portfolio positioning and characteristics relative to the agreed parameters) and ‘outcome-based’ analysis (quarterly monitoring of 3- month and 12-month performance on an individual portfolio basis). Process-based Risk Monitoring We use a portfolio monitoring tool, Bita Monitor, to generate automated daily analysis of portfolios to ensure risk parameters are adhered to. These reports analyse data by various factors to confirm each portfolio is within the agreed limits for: • Risk (portfolio volatility) • Concentration • Asset Class/Geographical positioning • Maximum holding weight • Buy list holdings Potential outliers are flagged using a traffic-light system to warn if a portfolio is either close to or breaching limits in any of these areas, highlighting where action needs to be taken by the portfolio manager on a daily basis. Exceptions to agreed parameters must be documented by the relevant portfolio manager and approved by independent monitoring of the Business Control and Risk Management team. Outcome-based Risk Monitoring In addition to ongoing monitoring of risk, asset allocation and stock selection through Bita Monitor, we carry out quarterly and annual portfolio performance reviews of all client portfolios thus ensuring strict adherence 13 © 2025 James Hambro & Partners. All rights reserved.  to the agreed parameters. Portfolio managers are made to review any performance outliers; both outperformance and underperformance relative to the mandate average or benchmark. Portfolio managers must provide relevant comments or known exceptions that have contributed to each performance outlier on a quarterly basis. Important risk factors Investment approach: All investment carries the risk of capital loss. No guarantee or representation is made that the investment approach used on behalf of these strategies will succeed. Market risks: The trading and investment strategies utilized are subject to market risk. Certain general market conditions – for example, a reduction in the volatility or pricing inefficiencies of the markets in which the portfolio is active – could materially reduce the strategy’s profit potential and good stocks could underperform due to generic weakness in confidence. Investments in equity securities: Equity market risk is the risk that a particular holding or holdings may fall in value. The value of an investment in a portfolio or fund will go up and down The prices of an investment or investments change in response to many factors, including the historical and prospective earnings of the issuer, the value of its assets, management decisions, demand for an issuer’s products or services, production costs, general economic conditions, interest rates, currency exchange rates, investor perceptions, market liquidity and sentiment Common stock and similar equity securities generally represent the most junior position in an issuer’s capital structure and, as such, generally entitle holders to an interest in the residual assets of the issuer, if any, remaining after all more senior claims to such assets have been satisfied. Holders of common stock generally are entitled to dividends only if and to the extent declared by the governing body of the issuer out of income or other assets available after making interest and any other required payments on more senior securities of the issuer. Investing in small or mid-cap equity securities: Certain strategies invest in small and mid-capitalization companies. Such companies may be more vulnerable to adverse business or economic events than larger, more established companies. In particular, these small and mid-capitalization companies may have limited: (i) product lines, (ii) history of operations, (iii) ability to raise additional capital, (iv) access to markets and financial resources, and (v) may depend upon relatively small management groups. These factors may make them more susceptible to market pressures and, therefore, small and mid-capitalization stocks may be more volatile and less liquid than those of larger companies. Illiquidity in certain markets: Certain strategies may invest in securities that later become illiquid or otherwise restricted. The strategy might only be able to liquidate these positions at disadvantageous prices, should the Portfolio Manager determine, or it becomes necessary, to do so. For example, substantial withdrawals from the strategy could require the strategy to liquidate its positions more rapidly than otherwise desired in order to obtain the cash necessary to fund the withdrawals. Illiquidity in certain markets could make it difficult for the strategy to liquidate positions on favourable terms, thereby resulting in losses or a decrease in the net asset value of the strategy. International investing: JH&P invests in companies established in developed countries, although these companies may have exposure to less developed economies. Investing in securities of non-U.S. issuers, positions which generally are denominated in foreign currencies involve both opportunities and risks not typically associated with investing in U.S. securities. These include: fluctuations in exchange rates of foreign currencies; possible imposition of exchange control regulation or currency restrictions that would prevent cash from being brought back to the United States; less public information with respect to issuers of securities; less 14 © 2025 James Hambro & Partners. All rights reserved.  governmental supervision of exchanges, brokers and issuers of securities; difficulties in obtaining and enforcing a judgment against a foreign issuer; different accounting, auditing and financial reporting standards; different settlement periods and trading practices; less liquidity and frequently greater price volatility in foreign markets than in the United States; imposition of foreign withholding and other taxes; and sometimes legal, operational and financial protections applicable to foreign sub custodial less advantageous arrangements. The cost of investing in securities of non-U.S. issuers can be higher than the cost of investing in U.S. securities. Investments in securities denominated in foreign currencies also involves the additional cost of converting currencies upon the purchase and sale of securities and the risk of movements in exchange rates, which can significantly impact the USD value. Emerging markets: The securities markets of emerging countries can be substantially smaller, less developed, less liquid and more volatile than the securities markets of the U.S. and other more developed countries. Disclosure and regulatory standards in many respects are less stringent than in the U.S. and other major markets. There also may be a lower level of monitoring and regulation of the markets and the activities of investors in certain less developed countries, and enforcement of existing regulations can be extremely limited. Emerging markets may have slower clearance and settlement procedures, higher transaction costs and investment restrictions that may restrict or delay trading. In addition, certain governments may require approval for, or otherwise restrict, the repatriation of investment income, capital or proceeds of sales of securities by foreign investors. war, governmental intervention, lack of capital, corruption, poor corporate management and limited resources are also common risks associated with investing in these markets. Sovereign debt may carry below investment grade credit ratings and be highly speculative. Defaults or restructurings of public and inter-bank indebtedness have occurred in several emerging markets, including Argentina, Brazil, Costa Rica, Ecuador, Indonesia, Malaysia, Mexico, Pakistan, Peru, Russia, South Korea, Vietnam, Thailand, Uruguay and Venezuela, as well as several African countries. There can be no assurance that foreign sovereign debt securities will not default or be subject to similar restructuring arrangements. Investments in securities of issuers located in emerging market countries can be more speculative than investments in securities of issuers located in developed countries and are subject to certain special risks. The political and economic structures in many of these countries may be in their infancy and developing rapidly, as such countries may lack the social, political and economic characteristics of more developed countries. Certain of these countries have in the past failed to recognise private property rights and have at times nationalized and expropriated the assets of private companies. Some countries have inhibited the conversion of their currency to another. The currencies of certain emerging market countries have experienced devaluations relative to the U.S. dollar, and future devaluations may adversely affect the value of assets valued in such currencies. Many emerging markets have experienced substantial, and in some periods, extremely high, rates of inflation for many years. Continued inflation may adversely affect the economics and securities markets of such countries. In addition, unanticipated political or social developments may affect the value of investments in these countries. The small size, limited trading volume and relative inexperience of the securities markets in these countries may make an investment in such countries illiquid and more volatile than investments in more developed countries, and the strategy may be required to establish special custodial or other arrangements before making investment decisions in these countries. There may be little financial or accounting information available with respect to issuers located in these countries, and it may be difficult as a result to assess the value or prospects of an investment in such issuers. Non US custody: In addition to the general risks associated with international investing described above, maintaining assets in foreign countries involves generally higher costs and greater risks than those associated with similar U.S. investments, particularly in the case of assets maintained in less developed countries. The scope and range of custodial services offered in many foreign countries may be more limited than in the U.S. and, as a result, assets may be maintained with banks, brokers and other financial institutions offering more limited custody services, and possessing less experience, less developed procedures for safekeeping of assets, 15 © 2025 James Hambro & Partners. All rights reserved.  poorer capitalization, and greater risks of bankruptcy, insolvency and fraud, than would typically be the case in the U.S. Assets maintained in certain emerging markets also may be subject to other types of risks that either are not present or less pronounced in the U.S. and other more established markets, including political and economic risks (including nationalization of foreign bank deposits or other assets, and poor political and economic infrastructure and stability), commercial and credit risks (including poorly developed and regulated banks and financial systems), liquidity risks (including restrictions on repatriation and convertibility of currencies), legal and regulatory risks (including risks relating to evolving and/or undeveloped legal systems and regulatory frameworks) and operational risks (including risks relating to maintenance of shareholder title, clearing and settlement procedures and market transparency. Transactions on non-U.S. exchanges are not regulated by U.S. governmental agencies, such as the SEC. Some non-U.S. exchanges, in contrast to U.S. exchanges, may be “principal markets” in which responsibility for performance is only that of the principal with whom a trader has entered into a transaction, and not of an exchange or clearing corporation. In some cases, a broker with whom the strategy enters into a transaction may in effect take the opposite side of trades made for the strategy. Because some non-U.S. exchanges generally lack a clearinghouse system such as that utilized by exchanges in the United States, market disruptions may be more likely to occur on non-U.S. exchanges. Currency risk: The value of foreign securities is affected by changes in currency rates, foreign tax laws (including withholding tax), government policies (in the US or outside), relations between nations, and trading, settlement, custodial and other operational risks. An increase in the strength of the U.S. dollar relative to other currencies may cause the value of investments to decline. Certain foreign currencies may be particularly volatile, and foreign governments may intervene in the currency markets, causing a decline in value or liquidity in foreign holdings whose value is tied to the affected foreign currency. In addition, costs will be incurred in connection with conversions between various currencies. ITEM 9. DISCIPLINARY INFORMATION There is nothing to report. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Our sole activity is investment management. Our related persons are identified in Form ADV Part 1. Our UK regulator, the Financial Conduct Authority, requires us to take all appropriate steps to identify and to prevent or manage conflicts of interest. These considerations apply equally in our role as a US registered Investment Adviser due to our role as a fiduciary and for the purposes of our Form ADV disclosure requirements. JH&Co, a wholly-owned subsidiary of JH&P, shares office space with JH&P. JH&Co has its own client base, none of which are U.S. resident clients. JH&Co provides financial planning services to its clients. A number of those clients have separately managed accounts with us for which we provide discretionary investment management services. This activity is separate from JH&Co activities. JH&P research, advice and recommendations are shared with JH&Co, but JH&Co financial planning is separated from JH&P portfolio management. JH&Co staff are associated persons of JH&P and comply with our written policies and procedures as required by Advisers Act Rule 206(4)-7 and our Code of Ethics. These include controls to ensure that JH&P confidential client information is not misused. 16 © 2025 James Hambro & Partners. All rights reserved.  We owe a fiduciary duty to our clients and act in the best interests of our clients. We have adopted a Code of Ethics (Item 11, below) that sets out the ethical standards of conduct that we require of our employees, including compliance with the U.S. federal securities laws. We require our Access Persons to comply with personal account dealing controls, noted in Item 11. We calculate the fee our clients pay based upon the valuation of the assets on our accounting system, which valuations are fully reconciled against the custodian. To address the conflict of interest rising out of our using our valuations to calculate fees, our auditors review our fee calculation methodology and sample calculations as part of their annual review. In addition to this, sample fee set ups are reviewed quarterly as part of compliance monitoring. Issues are addressed as they arise. ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING As a fiduciary, JH&P and its Supervised Persons must act in the best interests of clients and not misuse confidential client information. JH&P enforces a Code of Ethics compliant with Advisers Act Rule 204A-1. The Code of Ethics is communicated to all staff with regular compliance training, monitoring and testing. We have adopted a Code of Ethics (“Code”) under Advisers Act Rule 204A-1 to help us discharge our fiduciary duties to our clients and to protect against the misuse “confidential client information” (“non-public client information” as this term is defined in Rule 204A-1 including client holdings). Our Code establishes: standards of behaviour; a requirement to comply with applicable U.S. federal securities laws; a requirement that “Supervised Persons” (officers employees and partners) receive, read and acknowledge receipt of the Code; a requirement to report Code violations; CCO review of Code activities; and personal account trading (“PAD”) requirements for “Access Persons” and their “connected persons” (as defined in our Code), including initial and annual account and holding reports quarterly transaction reports and pre-clearance requirements. Policies and procedures on matters such as gifts, entertainment and inducements, and outside activities, are summarized in our Compliance Manual that signposts the relevant written policies and procedures required by the SEC pursuant to Rule 206(4)-7 under the Advisers Act. Our Code is part of the Compliance Manual and both form our written policies and procedures as contemplated by Rule 206(4)-7. From time-to-time, an access person may hold the same securities as Clients. The Code is designed to ensure that PAD activity does not interfere with acting in the best interest of clients and prevents the misuse of confidential client information. PAD activity is subject to pre-clearance and requests may be rejected. There is a 30 day minimum holding period. PAD activity is monitored to detect and address Code breaches. We have controls in place to prevent front running and “side by side” trading (clients and Access Persons trading at the same time) where there is any risk of client detriment. Certain of our Access Persons, their connected persons and their relatives that are not connected persons have their investment portfolios with us (“Connected Accounts”). Certain of our Portfolio Managers exercise discretion over Controlled Accounts. To address the conflict of interest in this, to prevent the misuse of non- public client information and to protect our clients, transactions in Controlled Accounts may not be effected while the beneficiary of such account or the person exercising discretion over such account has non-public client information. 17 © 2025 James Hambro & Partners. All rights reserved.  Connected Account activity is subject to restrictions, disclosure and monitoring. Such activity may take place only after the end of a blackout period following client trading activity. We reserve the right to impose further conditions upon such activity including the right to curtail portfolio activity. It is a violation of our Code for any person to act, fail to act or permit another person to act or fail to act in a way that would directly or indirectly control or influence a person exercising discretion over a Controlled Account. Persons who violate our written policies and procedures may be subject to disciplinary action including, but not limited to, written warnings, fines, disgorgement of profits and/or termination of employment, or referral to a regulator. A copy of our Code of Ethics is available on request. ITEM 12. BROKERAGE We execute trades on an agency basis using brokers which have been subject to our internal due diligence. We do not trade for our own account. We do not invest U.S. client assets in affiliated funds. We do not place orders to buy or sell securities with affiliated brokers. We do not recommend to, request or require clients to direct brokerage. When we trade, we comply with FCA Rules and the Advisers Act and the rules thereunder. FCA Rules require us to have to an order execution policy and to take all reasonable steps to obtain, when executing orders, the best possible results for our clients. We separate dealing from research. A broker may provide us with execution and research, but these will be under separate agreements and performance evaluated via separate processes and by different teams. Aggregation, allocation and order execution We are discretionary managers and the IMAs with our clients give us full discretion, subject to the investment restrictions stipulated in the IMA, to make investment decisions on behalf of the particular client portfolio. We believe that the separation between fund management and transaction execution means that our fund managers may concentrate on idea generation and portfolio construction and our dealers focus on adding value through quality execution. This separation also provides an in-built control in helping to seek and secure best execution for our clients’ portfolios. The trading strategy for the execution of discretionary orders is made by our internal dealing desk. All orders to be traded are passed electronically to our dealers via our fully audited order management system. In accordance with MiFID II legislation we fully unbundle research & execution costs / charges. All client orders are traded at an execution only commission rate (the broker charges us only an execution fee), giving our dealers impartiality when seeking the best possible outcome for a transaction. When trading for more than one portfolio or client, we may aggregate orders. These orders are allocated before an order is placed and our dealing software does not allow allocations to be changed after an order is submitted for execution. An allocation may be changed after execution only if there is a trade error (discussed below) and modified consistent with the manner in which the trade error is addressed. 18 © 2025 James Hambro & Partners. All rights reserved.  Cross trades We generally refrain from crossing stock between clients owing to the potential conflict of interest which this involves. On the rare occasions that crossing is in the interests of both parties and the trade meets best execution requirements for both clients, the cross trade would be executed through an independent broker in the market. This type of transaction can only take place where there is a change of beneficial owner. Best execution – seeking to obtain the best possible result JH&P are required to take all sufficient steps to obtain the best possible result (or ‘best execution’) when executing orders on behalf of our clients taking into account the execution factors. In order to achieve the best possible result when placing orders for our clients, we take into account the following execution factors: • • • • • • Price Costs Nature of The Order Likelihood of Execution & Settlement Speed of Execution Order Size In general, we consider total consideration (price and costs) will be the primary factor in attaining best execution. However, in some circumstances, orders, financial instruments or markets, we may appropriately determine that other execution factors are more important in obtaining the best possible execution result whilst ensuring that all clients are treated fairly. We use Bloomberg analytical tools and software to analyse market data to help determine the best strategy for each trade, taking into account varying factors such as liquidity and volatility. Once a trading strategy is decided, orders are instructed via FIX. Standard default low and high touch execution only commission rates are set out with our pre-approved brokers and maintained within our order management system (“OMS”). Low touch trading for smaller orders with a lower impact on Average daily volume, are dealt through direct market access (“DMA”) or via third party trading algorithms. Larger or more illiquid orders that may have a greater market impact, may be traded high touch, where the broker will work the order in the market to source liquidity and attempt to obtain a better execution price. Bonds - Bonds are generally traded with brokers via Bloomberg Fixed Income execution management system (TSOX) which is a ‘request for quote’ platform. Collective investment schemes - transactions in funds are conducted directly with the product provider or their transfer agent. Broker Approval and review Our policy is to maintain a choice of brokers which give access to venues and entities that offer the potential for James Hambro & Partners to obtain the best possible result for the execution of client orders on a consistent basis. We transact with pre-approved brokers as professional clients on an agency basis. All our brokers are subject to initial and ongoing due diligence, before being placed on our Approved Broker List (ABL). When choosing brokers, we prioritise the following factors which are key to the broker’s ability to deliver in line with our execution priorities: • Access to global regions 19 © 2025 James Hambro & Partners. All rights reserved.  • • • • • • • Past history in executing orders in particular asset classes; Access to trading venues and liquidity Electronic trading offering or capabilities Prevention of information leakage Quality of overall service provided Access to initial public offerings and new issues Creditworthiness of the institution. Our ABL comprises a mixture of large integrated investment banks and smaller country specific or niche firms. Order execution policy review Our goal is to ensure that our execution policy continues to provide for the best possible result for our clients. We monitor the effectiveness of our order execution arrangements and policy on a regular basis and in any event at least annually. Where necessary following these reviews we will amend our policy and where there are material changes will notify clients of those changes. Trade errors A trade error is an unintended action or omission in the course of order implementation and trading. Once a trade error is recognised, the person responsible for the error, or identifying it, must immediately notify the relevant senior manager and the Compliance Officer. We will correct the trade error promptly and efficiently protecting the interests of the client. Research JH&P separates dealing from research. We set a research budget on an annual basis following an assessment of the research requirements of JH&P as a whole. We have agreements with research brokers detailing the annual costs of accessing their research. The cost of research is passed on to the client as part of their fee up to a maximum of 5 basis points. Research is evaluated on an ongoing basis by the Investment Committee, with a full assessment of each research broker conducted annually. The assessment takes into account the quality, value added, access level and implied success of the decisions based on the research. The Investment Committee has the flexibility to add new research brokers and remove existing research brokers where they are not adding value to the investment process. Our Investment Committee conducts an annual review of research and research providers, based upon the following criteria. Quality of research • • • The quality of the analytical content the research provider produces at a company level. The quality and breadth of research beyond pure company analysis. This can include market insights and sector/thematic research that provides wider context and understanding of the investment landscape Analyst quality beyond written content including approachability and willingness to interact, and their relationship with and knowledge of the management teams of the companies they cover Quality of dissemination 20 © 2025 James Hambro & Partners. All rights reserved.  • • The ability of the sales contact to understand our requirements, filter information and ideas and present them in a coherent manner. The quality of the method of dissemination and ease of use including emails and web portals. Breadth of research • • • Whether this is the best quality of research relative to the price paid, taking account of the number of companies and sectors covered. Qualitative assessment of the value for money taking into account the breadth of research offered – number of companies covered, strategy and macro related output plus other value adding services The impact of adding value by way of thematic thought pieces and longer-term notes. The usefulness of comment on economics and strategy as well as individual company research and how these compare with the others in the market. Conferences • Access to a wide range of conferences from which JH&P may derive ‘on the ground’ perspective and help understand market sentiment. The Investment Committee will also compare the internal review with the industry standard to assess the relative performance of the research brokers. Soft commissions Please see section on research. ITEM 13. REVIEW OF ACCOUNTS Client portfolios are subject to ongoing review by the Portfolio Manager responsible for the account. They are assisted in ensuring compliance with the investment restrictions contained in the IMA by pre- and post-trade checking of those restrictions. These provide an alert for potential violations. Our systems provide an intra- day notices to compliance and an overnight re-evaluation of the restrictions to reflect end of day valuations. All exceptions and alerts are reviewed on a daily basis by the Operations team. All portfolios are also subject to our investment oversight procedures (see information on Bita Monitor in Item 8) to ensure adherence to the agreed parameters. We offer to all of our clients the opportunity to speak to our Portfolio Managers when requested and to participate in annual one-to-one meetings. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION JH&P pays third party solicitors for referrals outside of the United States. No such arrangements occur in the United States or involve U.S. clients. Should the Firm engage a third party solicitor involving clients in the United States, we will comply with the written disclosure requirements of Rule 206(4)-3. ITEM 15. CUSTODY We do not have custody as this term is defined and used in Advisers Act Rule 206(4)-2. Custody of the assets and cash in client portfolios is the responsibility of independent third party custodians who are appointed by the individual client or fund. Clients receive statements quarterly or monthly and are responsible for raising errors with the custodian. We reconcile our records with those of the custodian. 21 © 2025 James Hambro & Partners. All rights reserved.  ITEM 16. INVESTMENT DISCRETION We have discretionary authority to manage accounts on behalf of our clients. The scope and limits on this discretionary authority are stated in the agreed mandate for each client. We endeavour to ensure that all mandates for a particular strategy have similar limits on authority to ensure, as far as is possible having regard to individual client wishes, that each investment team manages all the monies which are entrusted to them in a similar style. ITEM 17. VOTING CLIENT SECURITIES JH&P are able to vote proxies for US clients. JH&P’s voting policy draws on relevant codes for the markets in which we invest and aims to encourage best-practice and positive change, while placing our clients’ capital in the best position to make attractive economic returns at a lower level of risk. A nominated Portfolio Manager within the Investment Team reviews voting recommendations provided by Institutional Shareholder Services (ISS), JH&P’s appointed proxy voting provider, to ensure our voting policy is followed. The client will need to instruct their appointed custodian to engage with ISS. Item 18. Financial Information We have nothing to disclose. ITEM 19. REQUIREMENTS FOR STATE-REGISTERED ADVISERS Currently, we have no state notice filings or registrations. 22 © 2025 James Hambro & Partners. All rights reserved.  Regulatory information This document is a Financial Promotion. This document does not constitute investment advice or a recommendation. Past performance is not a reliable indicator of future performance. The value of investments, and the income from them, may go down as well as up, so you could get back less than you invested. This material has been issued and approved by James Hambro & Partners LLP, which is authorised and regulated by the Financial Conduct Authority and is a registered investment adviser of the Securities and Exchange Commission. It is listed in the Financial Services Register with reference number 513246. James Hambro & Partners LLP is a limited liability partnership registered in England & Wales with number OC350134 and registered office at 45 Pall Mall, London SW1Y 5JG. A list of members is available on request. The registered mark James Hambro ® is the property of Mr J D Hambro and is used under licence. James Hambro & Partners LLP 45 Pall Mall, London, SW1Y 5JG +44 (0)20 3817 3500 23 © 2025 James Hambro & Partners. All rights reserved.