LEXINGTON HILL PARTNERS, LLC

Form ADV Part 2A – Disclosure Brochure Item 1: Cover Page March 2026 LEXINGTON HILL PARTNERS, LLC 5949 Sherry Lane, Suite 1170 Dallas, TX 75225 214-225-1891 This brochure provides information about the qualifications and business practices of Lexington Hill Partners, LLC. If you have any questions about the contents of this brochure or would like to receive a free copy, please contact us at 214-225-1891 or by emailing Cole Evans at cevans@lexingtonhillpartners.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Lexington Hill Partners, LLC is a registered investment advisor. Registration does not imply any level of skill or training. Additional information about Lexington Hill Partners, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov . The SEC’s website also provides information about any persons affiliated with Lexington Hill Partners, LLC who are registered, or are required to be registered, as investment adviser representatives of Lexington Hill Partners, LLC. 1  Item 2: Material Changes The last filing of this Firm Brochure was in June, 2025. Since the last filing of the Firm Brochure, there have been no material changes to report. 2  Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................................. 1 Item 2: Material Changes .................................................................................................................................. 2 Item 4: Advisory Services .................................................................................................................................. 4 Item 5: Fees and Compensation ......................................................................................................................... 8 Item 6: Performance-Based Fees and Side-By-Side Management ..................................................................... 9 Item 7: Types of Clients and Account Minimums ............................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss .............................................................. 9 Item 9: Disciplinary Information ......................................................................................................................12 Item 10: Other Financial Industry Activities and Affiliations ...........................................................................13 Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ...................13 Item 12: Brokerage Practices ...........................................................................................................................13 Item 13: Review of Accounts ...........................................................................................................................15 Item 14: Client Referrals and Other Compensation ........................................................................................15 Item 15: Custody .............................................................................................................................................15 Item 16: Investment Discretion .......................................................................................................................15 Item 17: Voting Client Securities ......................................................................................................................16 Item 18: Financial Information ........................................................................................................................16 3  Item 4: Advisory Services William Litton and Cole Evans co-founded Lexington Hill Partners, LLC (“Lexington Hill” or the “Firm”) in 2019. Litton and Evans retain exclusive ownership. Both Litton and Evans spent time at a previous RIA prior to founding Lexington Hill. Lexington Hill provides services to individuals and high-net worth individuals, which includes trusts and corporate entities related to those individuals and families, as well as businesses. Our commitment begins with a disciplined approach to asset allocation, portfolio management and advisory services. We offer wealth management services through an independent and transparent approach. Types of Advisory Services Our process begins with a free consultation to determine your current financial situation and the areas, if any, where our professional experience may be helpful. Lexington Hill offers a broad range of customized services to its clients including Limited Consulting Services (as defined below) and investment management. Limited Consulting Services Families with significant net worth face complex issues that require multiple areas of expertise. For some of our families, we provide a “concierge-level” of customized service which we call “Limited Consulting Services”. Together with the family’s other professionals, we help clients create, implement, and monitor strategies and reporting related to investments, philanthropy, generational wealth transfer, estate planning, and income taxes. Our Limited Consulting Services are offered under a Limited Consulting Agreement. These services are specifically tailored to the family and its needs and includes, but is not limited to, the following: Investment planning, due diligence, management, and portfolio construction Life, disability, long-term care and property/casualty insurance consulting • Personal budgeting and cash flow planning • Personal financial statement preparation and maintenance • Debt, risk management and asset protection consultation • • • Review and administration of unmanaged assets • Financial independence planning • Educational funding • Tax coordination and facilitation • Business investment analysis and succession planning • Foundation management and facilitation • Estate planning Investment Management Our investment philosophy is primarily that of a long-term, low-turnover strategy in a balanced, well- diversified portfolio. We believe we can achieve diversification and meet client objectives through the appropriate allocation of exchange traded funds, mutual funds, bonds and alternative investments. Our Investment Advisory Agreement allows us to execute trades for your accounts without requiring your 4  prior approval. This is known as discretion. Your Investment Advisory Agreement will detail the accounts for which we provide investment advice and the accounts on which we will charge an advisory fee. Lexington Hill provides ongoing investment advisory services including the following: • Development of an asset allocation strategy that considers risk tolerance, time horizon, and financial objectives • Recommendation of specific investments • Placement of trades with your custodian • Assistance with custodian paperwork and follow-up on requested service issues • Regular portfolio monitoring throughout the year Custody. As part of its investment advisory services and as discussed later in this Brochure at Item 15, Lexington Hill recommends that Fidelity and/or Schwab and/or American Funds and/or my529 serve as the broker-dealer/custodian for clients’ investment management assets. Broker-dealers such as Fidelity, Schwab, American Funds, and my529 may charge brokerage commissions and/or transaction fees for effecting securities transactions. In addition to Lexington Hill’s investment management fee, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The fees charged by Fidelity, Schwab, American Funds, and my529 as well as the charges imposed at the mutual fund and exchange traded fund level, are in addition to Lexington Hill’s advisory fee referenced in Item 5 below. Independent Managers. When suitable, Lexington Hill allocates a portion of a client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets. Lexington Hill shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Factors that Lexington Hill considers in recommending Independent Manager(s) include the client’s designated investment objective(s) and the manager(s’) management style, risk profile, past performance, reputation, reporting, client service, pricing, and research. Please Note: The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, Lexington Hill’s advisory fee as set forth in the fee schedule in Item 5 below. Portfolio Activity. Lexington Hill has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Lexington Hill will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, Lexington Hill will determine when extended periods of time dictate that changes to a client’s portfolio are neither necessary nor prudent. Of course, as discussed below, there can be no assurance that investment decisions made by Lexington Hill will be profitable or equal any specific performance level(s). Clients can impose restrictions on investing in certain securities or types of securities by notifying Lexington Hill of such restrictions in writing. Private Fund Investments and Management Lexington Hill provides investment advice regarding private investment funds. Lexington Hill’s role relative to 5  private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) will be included as part of “assets under management” for purposes of Lexington Hill calculating its investment advisory fee if such assets are included in the client’s Investment Advisory Agreement with Lexington Hill. Lexington Hill’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Risk Factors: Private investment funds involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints, and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement or other similar documents, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Retirement Account Services Commented [SD1]: As discussed we want to add this related to PTE 2020-02. LHP is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (“IRAs”) pursuant to the Employee Retirement Income and Securities Act (“ERISA”), and regulations under the Internal Revenue Code of 1986 (“the Code”), respectively. As such, we are subject to specific duties and obligations under ERISA and the Code that include, among other things, restrictions concerning certain forms of compensation. We may assist you with retirement plan accounts and this assistance may present a conflict of interest. When you leave an employer there are typically four options regarding an existing retirement plan account and you may use a combination of these options; 1) if permitted, leave the funds in your former employer’s plan, 2) if roll overs are permitted and you have new employer with a plan available, roll over the funds to your new employer’s plan, 3) roll over to an Individual Retirement Account (“IRA”), or 4) withdraw or cash out your funds from the plan which may have adverse tax consequences depending on your age. At a minimum, Investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. LHP encourages you to discuss your options and review the above-mentioned considerations with an accountant, third-party administrator, investment advisor to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. When we recommend that you roll over your retirement plan assets into an account to be managed by us, such a recommendation creates a conflict (benefit to us) when we earn an advisory fee on your rolled over funds. You are under no obligation to roll over retirement plan assets to an account managed by us. Other Services Lexington Hill provides custom services and solutions to its clients on a case-by-case basis as mutually agreed to by the client and Lexington Hill. These include (but are not limited to) administrative services, bookkeeping, acting in the capacity of a trustee, and professional services coordination and communications. We provide limited consulting services primarily to high-net-worth individuals and families, which include trusts and corporate entities related to those individuals and families, as well as businesses. 6  Lexington Hill does not provide tax preparation, tax advice, or legal counsel. We encourage you to consult your accountant or attorney on all tax and legal matters, respectively. Client Obligations In performing our services, Lexington Hill shall not be required to verify any information received from the client or from the client’s other professionals, and Lexington Hill is expressly authorized to rely thereon. Lexington Hill collects, documents and maintains relevant client background information, including the client’s financial goals, objectives, and risk tolerance. Lexington Hill conducts regular reviews of each client account, no less than every three years, to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; moreover, each client is advised that it remains his/her/its responsibility to notify Lexington Hill promptly if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our previous recommendations and/or services. Current Client Assets As of December 31, 2025, Lexington Hill had $263,397,108 in discretionary assets under management and $15,040,609 in non-discretionary assets under management for a total of $278,437,717 in regulatory assets under management. Miscellaneous We do not serve as an attorney or accountant, nor is Lexington Hill affiliated with any such service provider and no portion of our services should be construed as such. Accordingly, we do not prepare contracts, estate planning documents or tax returns. To the extent requested by a client, we recommend the services of other professionals for certain non-investment implementation purposes (e.g., attorneys, accountants, insurance brokers). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Lexington Hill and/or its representatives. Lexington Hill does not receive any compensation for such recommendations or referrals. Please Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Note - Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Thus, a client or prospective client can obtain many of the funds utilized by Lexington Hill independent of engaging Lexington Hill as an investment advisor. However, if a client or a prospective client determines to do so, he/she will not receive Lexington Hill’s initial and ongoing investment advisory services. Use of DFA Mutual Funds: Lexington Hill utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through investment advisers. Thus, if the client terminates Lexington Hill’s services and does not transition to another adviser who utilizes DFA funds, restrictions regarding 7  additional purchases of, or reallocation among other, DFA funds will apply. Item 5: Fees and Compensation Limited Consulting Services Fees The scope of services to be provided is outlined in a Limited Consulting Agreement. The fee for these services is charged on a quarterly basis in advance, at a rate based on our estimated involvement and the complexity of services. Lexington Hill does not maintain an account or fee minimum. Fees are negotiable. Lexington Hill will provide related consulting services regarding non-investment related matters, such as estate planning and insurance coordination, on a separate and additional fee basis per the terms and conditions of a Limited Consulting Agreement. Similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. Fees agreed upon but not specifically included in a Limited Consulting Agreement will be billed in an additional invoice outlining the limited services provided on an ad-hoc basis. Investment Management Fees Unless otherwise negotiated, Lexington Hill establishes all new client relationships’ investment management fees at an annual rate based on the value of the client’s total household portfolio of assets under management (see table below). Portfolio Value First $1,000,000 Next $4,000,000 Next $20,000,000 Annual Rate 0.75% 0.50% 0.25% Over $25,000,000 0.15% Fees are calculated on a cumulative basis. For example, a client with $5,600,000 under management would pay an annualized rate of 0.75% on $1,000,000, 0.50% on $4,000,000 and 0.25% on $600,000. Fees are calculated based on the portfolio valuation as determined by the account custodian, third-party administrator or portfolio management system at the close of market on the last business day of each quarter. Not all of our clients are on the same fee schedule, as our fees, and the assets we bill on, have changed over the life of the firm. Additionally, our fees are negotiable, and we reserve the right to negotiate any fees based on numerous factors. Therefore, some clients pay more or less than others for similar services. Your investment management fee schedule is determined prior to any investment management fees being incurred and is outlined on Exhibit B of your signed Investment Advisory Agreement. Any changes to your fee schedule must be amended in writing on an updated Exhibit B. Fees are negotiable. Billing and Collecting Investment Management Fees Clients pay advisory fees in advance. Fees are calculated based on the value of assets under management and 8  are billed quarterly. After the first of each quarter (and after final reconciliation of the prior quarter is complete), fees are calculated and paid. Clients may elect to have fees either directly deducted from their portfolio account(s) or paid from a separate, non-managed account via a direct billing statement. Please refer to Item 15 – “Custody” for further information on our ability to deduct fees directly from client accounts. Termination of Advisory Relationship and Refund of Prepaid Fees The Investment Advisory Agreement, and Limited Consulting Agreement are effective until terminated by either party upon delivery of written notice. At the date of termination, any prepaid and unearned fees will be refunded to the client on a pro rata basis. Upon request, we will also provide an accounting on a year-to-date basis in the event you terminate our investment advisory services during a quarter. Additional Fees Our investment management fee is separate from any transaction, exchange, wire transfer, margin interest or account fee charged by your qualified custodian. Some custodians charge a transaction fee on certain mutual funds and therefore you will pay more to purchase or sell these funds than if we went directly to these fund families on your behalf. To the extent that your assets are invested in mutual funds (including money markets) and exchange traded funds (also known as ETFs), our fee for monitoring those assets is in addition to the fees charged by those fund companies. Even a “no load” or “load waived” mutual fund charges an internal fee to compensate the manager of the fund and to pay for the fund company’s administrative expenses. Please refer to each fund’s prospectus for a detailed discussion of the fees and expenses charged by the fund company. Compensation for the Sale of Securities Lexington Hill does not receive commissions on the sale or purchase of any other investment products or securities. Item 6: Performance-Based Fees and Side-By-Side Management Lexington Hill does not receive a performance-based fee structure (fees based on a share of capital gains or on capital appreciation of the assets of a client). Item 7: Types of Clients and Account Minimums We provide portfolio management services and limited consulting services primarily to high-net-worth individuals and families, including trusts and corporate entities related to those individuals and families, as well as businesses, including but not limited to other investment advisers through sub-advisory arrangements. These client relationships vary in scope and length of service. Lexington Hill does not impose account minimums. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Prior to entering into any investment, you should carefully consider the following: 9  Investing in securities involves risk of loss, which you should be prepared to bear. 1. 2. Securities markets experience varying degrees of volatility. 3. Over time, the value of your assets will fluctuate and at any time be worth more or less than the amount you originally invested. 4. Mutual funds and ETFs are not guaranteed or insured by the FDIC or any other government agency. 5. Past performance is not a reliable indicator of future performance, although it may help you assess a fund's volatility over time. 6. All mutual funds and ETFs have costs that lower your investment returns. Philosophy of Investing One way that we manage risk is by determining an appropriate asset allocation (i.e., the balance between stocks, bonds, cash and alternative investments) based on your goals, objectives, time horizon and risk tolerance, and then diversifying the holdings in your portfolio based on that allocation. We typically achieve diversification through a variety of mutual funds and ETFs. We consider a fund’s annual expense ratios when deciding whether to buy it or buy a comparable security within its respective peer group. Other selection criteria include style, consistency of adherence to style, management tenure, historical performance, and consistency of historical performance. Frequently Used Investment Vehicles Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus a client can lose money investing in mutual funds. All mutual funds have internal expenses and fees that lower investment returns. The funds can be of bond “fixed income” nature or stock “equity” nature (see below): Bond Funds: Bond funds have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields. Unlike money market funds, the SEC’s rules do not restrict bond funds to high quality or short-term investments. Because there are many different types of bonds, bond funds can vary dramatically in their risks and rewards. Stock Funds: Although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, historically stocks have performed better over the long term than other types of investments — including corporate bonds, government bonds, and treasury securities. Overall “market risk” poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons—such as the overall strength of the economy or demand for particular products or services. Even interest rates can affect stock prices. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, like stocks, with pricing occurring throughout the trading day. ETFs, like mutual funds, contain internal expenses and fees which lower investment returns. Tax Consequences of Funds - When investors buy and hold an individual stock or bond, the investor must pay income tax each year on the dividends or interest the investor receives. However, the investor will not have to pay any capital gains tax until the investor actually sells and unless the investor makes a profit. Mutual funds are different. When an investor buys and holds mutual fund shares, the investor will owe 10  income tax on any ordinary dividends in the year the investor receives or reinvests them. In addition to owing taxes on any personal capital gains when the investor sells shares, the investor may also have to pay taxes each year on the fund’s capital gains because the law requires mutual funds to distribute capital gains to shareholders if they sell securities for a profit that cannot be offset by a loss. Corporate and Municipal Bonds: Corporate bonds are debt obligations issued by companies to finance their respective business operations. Municipal bonds are securities issued by local governments and agencies usually to finance public projects such as roads, schools, hospitals, water infrastructure, and stadiums. For both corporate and municipal bonds, the debt holder generally receives interest payments while the bond is in existence. When the bond’s duration comes to an end -- this is called “maturity” – the borrowing entity then repays the principal amount of the bond. For corporate bonds, the interest paid is typically taxed at an ordinary income tax rate. The interest paid on municipal bonds is frequently free of state or federal income tax for residents of the issuer’s state, but you should consult with your tax advisor for specifics about your own situation. There are many risks associated with buying individual bonds and groups of bonds called bond funds. Treasury Bonds: Treasury bonds are considered low-risk investments that are generally risk-free when held to maturity, since being backed fully by the U.S. government makes the odds of default extremely low. Alternative Investments: An alternative investment is an investment product other than traditional stocks, bonds and cash. In general, alternative investments can include tangible assets (things you can touch like art, wine, antiques, coins, or stamps). It can also include certain financial assets like commodities, private equities, hedge funds, venture capital, and financial derivatives. Many of these investments carry a high degree of risk, are illiquid and require extensive analysis before purchasing. Other Types of Investments We Recommend Hedge Funds: When suitable for particular clients, Lexington Hill recommends that certain qualified and accredited clients participate in hedge fund products. In addition, some of our family office clients participate in other hedge funds that are not suitable for our investment advisory clients and/or whose minimum investments are too high for our investment advisory clients to consider. Private Equity, Venture Capital Funds and Limited Partnerships: Some of our clients frequently invest in private equity and private equity funds. Private equity is an asset class consisting of equity and debt in operating companies that are not publicly traded on a stock exchange. Some of our clients also frequently invest in venture capital or venture capital funds. This includes what is commonly referred to as “angel investing.” Companies raising money through this method begin with a seed round (usually convertible debt) and progress through a series of equity rounds of fund raising. The ultimate goal of this type of investment is for the company to sell successfully to another company or to take their shares public in an initial public offering. With the exception of a small number of unaffiliated investments, these types of illiquid investment opportunities are usually brought to Lexington Hill by our clients. In these instances, our role is to coordinate documents and assist the client with wiring funds. In certain instances, we will “sit at the table” with the client during the due diligence process or even take the initial meeting as part of a screening process. Although the clients who bring these opportunities to our attention are often capable of evaluating this high-risk class of 11  investments without our assistance, they often request our participation in their investment process. Risk Disclosure: Alternative investment products, including real estate investments, private equity, hedge funds and venture capital, involve a high degree of risk, often engage in leveraging and other speculative investment practices that increase the risk of investment loss, can be highly illiquid, may not be required to provide periodic pricing or valuation information to investors, involve complex tax structures and delays in distributing important tax information, are not subject to the same regulatory requirements as mutual funds, charge high fees that may offset any trading profits, and in many cases the underlying investments are not transparent and are known only to the investment manager. Alternative investment performance can be volatile. An investor could lose all or a substantial amount of his or her investment. Often, alternative investment fund managers have total trading authority over their funds or accounts. The use of a single manager could mean a lack of diversification and, consequently, higher risk. There is often no secondary market for an investor’s interest in alternative investments and there is little prospect for one to develop. There may be restrictions on transferring interests in any alternative investment. Some alternative investment products execute a substantial portion of their trades on non- U.S. exchanges. Investing in foreign markets entail risks that differ from those associated with investments in U.S. markets. Additionally, alternative investments can entail commodity trading, which involves a substantial risk of loss. Cybersecurity Risk: Lexington Hill and its service providers are subject to operational and information security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information or various other forms of cybersecurity breaches. Cybersecurity attacks affecting Lexington Hill and its service providers can adversely impact Clients. For instance, cyberattacks may interfere with the processing of transactions, cause the release of private information about Clients, impede trading, subject Lexington Hill to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which Clients accounts invest in, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damages, and loss from damage or interruption of systems. Although Lexington Hill has established its systems to reduce the risk of these incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Lexington Hill does not directly control the cybersecurity measures and policies employed by third-party service providers or those of its clients. Item 9: Disciplinary Information Neither Lexington Hill nor employees of the Firm has had any civil or criminal actions brought against them for professional services provided, and neither Lexington Hill nor any of its employees has had any proceedings before the SEC or any other federal, state or foreign financial regulatory agencies or authorities. In addition, neither Lexington Hill, nor any of its employees, has been involved in any proceedings before a self-regulatory organization. 12  Item 10: Other Financial Industry Activities and Affiliations We do not receive fees or commissions from any other companies – financial services, insurance or otherwise. The only fees we receive are those paid directly from our clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Lexington Hill adopted a Code of Ethics for all employees, and it is available to any client or prospective client upon request. Our Code of Ethics describes our standard of business conduct and fiduciary duty to our clients. This Code includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts, and personal securities trading procedures among other things. All employees must acknowledge the terms of the Code of Ethics annually. Lexington Hill employees are allowed to buy, sell, or hold the same securities in their personal accounts that we recommend to, and purchase for, our clients. The Code is designed to assure that our employees’ personal securities transactions will not interfere with our responsibility to make decisions in the best interest of our advisory clients. It also guides how we implement those investment decisions, while also allowing employees to invest for their own personal portfolios. Our Code of Ethics requires pre-clearance of private placements and initial public offerings. Nonetheless, because in some circumstances our Code would permit employees to invest in the same securities as clients, we monitor employee trading to prevent conflicts of interest between ourselves and our clients. Lexington Hill’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s) or to maintain such an investment. Lexington Hill’s Chief Compliance Officer, Cole Evans, remains available to address any questions that a client or prospective client has regarding the above arrangement and any corresponding perceived conflict of interest that such arrangement creates. Employees are required to report any outside business activities generating revenue. If any are deemed to conflict with clients, such conflicts will be fully disclosed, or the employee will be directed to cease this activity. Item 12: Brokerage Practices In the event that the client requests that Lexington Hill recommend a broker-dealer/custodian for execution and/or custodial services, Lexington Hill recommends that investment advisory accounts be maintained at Schwab and/or Fidelity and/or American Funds and/or my529. Prior to engaging Lexington Hill to provide investment management services, the client will be required to enter into an Investment Advisory Agreement with Lexington Hill setting forth the terms and conditions under which Lexington Hill shall advise on the client's assets and a separate custodial/clearing agreement with each designated broker-dealer/custodian. Factors that Lexington Hill considers in recommending Schwab and/or Fidelity and/or American Funds and/or my529 (or any other broker-dealer/custodian to clients) include the historical relationship with Lexington Hill, financial strength, reputation, execution capabilities, pricing, research, and service. Although the transaction fees paid by Lexington Hill’s clients shall comply with Lexington Hill’s duty to obtain best execution, a client may pay a transaction fee that is higher than another qualified broker-dealer might charge to effect the same transaction where Lexington Hill determines, in good faith, that the transaction fee is 13  reasonable. In seeking best execution, the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker- dealer’s services, including the value of research provided, execution capability, transaction rates, and responsiveness, as well as the client’s existing relationship and/or preference. Accordingly, although Lexington Hill will seek competitive rates, it will not necessarily always obtain the lowest possible rates for client account transactions. Non-Soft Dollar Research and Benefits: Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Lexington Hill can receive from Schwab and/or Fidelity and/or American Funds and/or my529 (or another broker-dealer/custodian, investment manager, platform or fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist Lexington Hill to better monitor and service client accounts maintained at such institutions. Included within the support services obtained by Lexington Hill can be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software, and/or other products used by Lexington Hill in furtherance of its investment advisory business operations. Certain of the above support services and/or products assist Lexington Hill in managing and administering client accounts. Others do not directly provide such assistance but rather assist Lexington Hill to manage and further develop its business enterprise. Lexington Hill’s clients do not pay more for investment transactions effected and/or assets maintained at Schwab and/or Fidelity and/or American Funds and/or my529 as a result of this arrangement. There is no corresponding commitment made by Lexington Hill to Schwab and/or Fidelity and/or American Funds and/or my529 or any other any entity, to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. Directed Brokerage. Lexington Hill recommends that its clients utilize the brokerage and custodial services provided by Schwab and/or Fidelity and/or American Funds and/or my529. Lexington Hill generally does not accept directed brokerage arrangements (when a client requires that account transactions be effected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Lexington Hill will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by Lexington Hill. As a result, a client may pay higher commissions or other transaction costs or greater spreads or receive less favorable net prices on transactions for the account than would otherwise be the case. Please Note: In the event that the client directs Lexington Hill to effect securities transactions for the client’s accounts through a specific broker- dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements available through Lexington Hill. Higher transaction costs adversely impact account performance. Please Also Note: Transactions for directed accounts will be executed following the execution of portfolio transactions for non-directed accounts. Order Aggregation. Transactions for each client account will be effected independently. The Firm may (but is 14  not obligated to) combine or “bunch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Lexington Hill’s clients any differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. Lexington Hill shall not receive any additional compensation or remuneration as a result of such aggregation. Item 13: Review of Accounts The Chief Compliance Officer, or the Chief Compliance Officer’s designee, conducts sample reviews of managed accounts quarterly. All clients are encouraged to meet with the Firm at least annually. Additional reviews could be triggered by events such as a client meeting, change in a client's risk tolerance, financial position or investment objective, change in a company or fund's management, unusual market or economic circumstances, or other unforeseen events. Item 14: Client Referrals and Other Compensation Lexington Hill does not compensate individuals or entities for prospective client introductions. Item 15: Custody Lexington Hill has a form of custody of client assets to the extent that the Firm shall have the ability to deduct its advisory fee from the client’s custodial account on a quarterly basis. Clients are provided with transaction confirmation notices and a summary account statement directly from the custodian (i.e., Schwab, Fidelity, American Funds, my529 etc.) at least quarterly. To the extent that Lexington Hill provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by Lexington Hill with the account statements received from the account custodian. The account custodian does not verify the accuracy of Lexington Hill’s advisory fee calculation. Lexington Hill engages in other practices and/or services on behalf of some its clients (including the utilization of client logins to certain financial accounts to update client financial statements) that require disclosure at the Custody section of Part 1 of Form ADV, certain of which practices and/or services are subject to an annual surprise CPA examination in accordance with the requirements of Rule 206(4)-2 under the Investment Advisers Act of 1940. Item 16: Investment Discretion Our Investment Advisory Agreement provides that the client grant complete investment discretion to Lexington Hill. This limited power of attorney allows us to determine both the securities purchased and sold and the amounts of those purchases and sales. You can limit or restrict our discretion in writing. Typical restrictions a client places on us are to hold a stock or fund they have historically held and do not want to sell either because of tax implications or emotional attachment to the investment or the circumstance under which they acquired the investment (e.g., inheritance). 15  Item 17: Voting Client Securities In accordance with our policies and procedures, Lexington Hill does not have any authority to, and does not, vote proxies on behalf of advisory clients. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolio. If you do not understand what you are being asked to vote on, we will discuss the issues with you at your request and allow you to make an informed investment decision. Item 18: Financial Information No financial conditions exist that are reasonably likely to impair our ability to meet contractual commitments to clients. Since we do not require our clients to prepay their management fees six months or more in advance, we are not required to provide audited financial statements. 16