Overview

Assets Under Management: $1.3 billion
Headquarters: CHICAGO, IL
High-Net-Worth Clients: 9
Average Client Assets: $78 million

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients

Clients

Number of High-Net-Worth Clients: 9
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 53.72
Average High-Net-Worth Client Assets: $78 million
Total Client Accounts: 2,876
Discretionary Accounts: 2,876

Regulatory Filings

CRD Number: 107066
Filing ID: 1971085
Last Filing Date: 2025-03-28 08:00:00
Website: https://acaglobal.com

Form ADV Documents

Primary Brochure: OAK RIDGE INVESTMENTS, LLC FORM ADV PART 2 - 03_2025 (2025-03-26)

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Item 1 Cover Page Form ADV Part 2A Oak Ridge Investments, LLC 10 South LaSalle, Suite 2130 Chicago, Illinois 60603 312-857-1040 www.oakridgeinvest.com This brochure provides information about the qualifications and business practices of Oak Ridge Investments, LLC. If you have any questions about the contents of this brochure, please contact us at 312-857-1040. 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. Additional information about Oak Ridge Investments, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Oak Ridge Investments, LLC is an investment adviser registered with the SEC. This registration does not imply a certain level of skill or training. March 26, 2025 1 Item 2 Material Changes We have not made any material changes to this brochure, dated March 26, 2025, since our last brochure dated October 10, 2024. 2 Item 3 Table of Contents Item 1 Cover Page ................................................................................................................................ 1 Item 2 Material Changes ...................................................................................................................... 2 Item 3 Table of Contents ...................................................................................................................... 3 Item 4 Advisory Business .................................................................................................................... 4 Item 5 Fees and Compensation ............................................................................................................ 6 Item 6 Performance-Based Fees and Side-by-Side Management ........................................................ 8 Item 7 Types of Clients ........................................................................................................................ 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 9 Item 9 Disciplinary Information ........................................................................................................ 13 Item 10 Other Financial Industry Activities and Affiliations ............................................................... 14 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 14 Item 12 Brokerage Practices ................................................................................................................ 15 Item 13 Review of Accounts ................................................................................................................ 19 Item 14 Client Referrals and Other Compensation .............................................................................. 19 Item 15 Custody ................................................................................................................................... 20 Item 16 Investment Discretion ............................................................................................................. 20 Item 17 Voting Client Securities .......................................................................................................... 21 Item 18 Financial Information ............................................................................................................. 23 Additional Information – Privacy Notice ................................................................................................. 24 3 Item 4 Advisory Business Oak Ridge Investments, LLC (“Oak Ridge,” “We” or the “Firm”) is an investment advisory firm founded in 1989. Our founder and CEO, David Klaskin, owns slightly less than 40% of the Firm. We focus, and predominantly limit, our direct advice to analyzing and recommending equity stocks traded on United States stock exchanges for our clients, currently in the strategies described below. Equity Strategies As of the date of this document, the Firm manages five diversified equity strategies (the “Equity Strategies”) for separately managed accounts and manages, or is available to manage, unified managed accounts: • Small/Mid Cap Growth invests in securities with a market cap range at the time of initial purchase similar to its benchmark, the Russell 2000® Growth Index. • Mid Cap Growth has a market capitalization guideline at the time of initial purchase of being in line with its benchmark, the Russell Midcap Growth® Index. • Large Cap Growth holds stocks with a market capitalization of over $3 billion at the time of purchase. The strategy’s benchmark is the Russell 1000® Growth Index. • All Cap Growth purchases securities with a market capitalization of $500 million or greater. The strategy’s benchmark is the Russell 3000® Growth Index. • Dividend Growth is a concentrated portfolio, holding 25-35 securities, with a minimum capitalization of $5 billion. The benchmark for this strategy is the S&P 500 Index and the portfolio’s goals include seeking to buy stocks with a growing dividend per share and exceeding the dividend yield rate for the index. The primary objective of our Equity Strategies is long-term capital appreciation. Our Dividend Growth investment strategy also has dividend yield as a primary objective. We generally maintain accounts fully invested in equity securities, which we define as holding less than 10% in cash and equivalents. Additional information about the Equity Strategies can be found in Item 8, Methods of Analysis, Investment Strategies and Risk of Loss. Our clients in the Equity Strategies can access our portfolio management through multiple channels, including directly through the Firm or through one or more programs sponsored by unaffiliated entities (“Sponsored Programs”). The unaffiliated entities (each a “Sponsor”) can be a bank, broker-dealer or investment advisor. There are three types of Sponsored Programs: 1) Dual Contract programs where the client signs separate agreements with the Sponsor and with Oak Ridge; 2) Sub-advised programs, including wrap fee programs, in which the client signs an agreement only with the Sponsor and the Sponsor has the discretion to engage Oak Ridge to advise a separate account on behalf of clients within the program; or 3) Unified Managed Account (“UMA”) programs in which Oak Ridge provides a Sponsor with a model portfolio, but does not have discretion over 4 client assets, records of individual client holdings and typically information about individual clients. Oak Ridge invests discretionary assets for each account in the Equity Strategy(ies) chosen by a client using Oak Ridge’s Equity Strategy model portfolio. Oak Ridge also considers each client’s objectives, individual needs and restrictions. Oak Ridge manages the equity holdings and the overall asset allocation between equities and cash, but does not select money market funds, mutual funds or ETFs for clients. You, your custodian, broker-dealer or investment advisor should select a money market fund or cash equivalent that is appropriate for your Oak Ridge account. We will accept accounts with reasonable restrictions (see Item 16, Investment Discretion) and will follow client direction for individualized treatment of securities, such as for tax gain or loss sales or certain limited other purposes. We will also work with clients on restrictions for clients who desire their accounts be managed in a socially responsible way as however the clients may want to define that. Oak Ridge will also provide input on managing an account, if requested, in accordance with environmental, social and governance standards (“ESG”) as the client may want to define or design that. Oak Ridge will also consider other circumstances, such as ticket charges if applicable, when trading client portfolios. You should contact us, either directly or through your Program Sponsor, to inform us of any changes in your circumstances or restrictions that would affect how we manage your account. Wrap Fee and Sponsored Programs – Wrap fee accounts and other Sponsored Program accounts may be billed to you as a single fee by the Sponsor. The Sponsor will pay Oak Ridge’s investment advisory fee out of the wrap fee it collects, with the remainder being retained as its fees and/or advisory or consulting fees and in lieu of the Sponsor’s commissions and custody fees. Cash needs in these accounts may be slightly higher than in other accounts due to the combined fees (for the Sponsor and Oak Ridge) periodically deducted directly from the portfolio assets. Additional information about fees can be found in Item 5, Fees and Compensation. In determining whether to establish a Sponsored Program account, whether a wrap fee program or otherwise, you should be aware that the overall costs may be higher or lower than you might incur by accessing the same services outside of the Sponsored Program. In evaluating whether or not a wrap fee program or arrangement is appropriate for your needs, you should consider factors such as the size of the account, the expected frequency of transactions by the advisor in the investment strategy or due to cash flows initiated by you, and your investment objectives. Rebalancing transactions due to cash flows in or out of your account, especially in smaller accounts, may affect performance and could incur higher than normal trading expenses (including commissions if in place) both in amount and as a percentage of your account value. These factors could influence your decision whether or not to choose a wrap account or even whether to engage in cash flow transactions on as frequent a basis. 5 UMA Programs – Oak Ridge has agreements with other investment advisors who use model portfolios provided by the Firm as the basis for investment strategies that they offer to their clients. Oak Ridge does not create these models for any specific individual(s) or the particular needs of any client; but based upon what Oak Ridge believes is an appropriate allocation and weighting of securities for each strategy. The UMA investment advisor has discretion to determine when, how and to what extent to act upon Oak Ridge’s recommendations. Assets under Management; Assets under Administration As of December 31, 2024 we had assets under administration of approximately $2.09 billion which included discretionary client assets under management of approximately $1.31 billion and an additional approximately $787 million advised on a non-discretionary basis in UMA accounts. Item 5 Fees and Compensation Clients pay Oak Ridge asset-based investment advisory fees. Fees are determined by agreement with the client or with a Program Sponsor. Oak Ridge does not charge performance-based fees to clients in our Equity Strategies or currently to any of its clients. The fees shown in the table below are those that are listed in the Firm’s standard investment management agreement for separately managed accounts, including some Sponsored Program clients who have their firm negotiate fees directly with Oak Ridge. See below for fee information for other Sponsored Programs. Standard Fee Schedule All Cap Dividend Growth First $10 million Next $15 million Next $25 million Over $50 million Mid Cap 0.85 0.75 0.70 0.65 Small/Mid Cap 0.95 0.90 0.80 0.70 Large Cap 0.65 0.55 0.50 0.45 0.80 0.70 0.65 0.60 0.75 0.65 0.60 0.55 Fees are negotiable and may vary based on the size of the account, related clients, and other factors. Clients can choose to be billed directly or to have fees paid through their investment account. If they choose the latter, Oak Ridge will communicate directly with the custodian for payment. Some arrangements will depend on the cooperation of the custodian chosen by the client. As a result of being negotiable, final fees charged are usually different than these listed fees. Fees are generally billed quarterly in advance based on assets as of the end of the previous calendar quarter. Assets in the account include securities, cash or cash equivalents and accrued income. New accounts billed in advance will be billed based on their beginning assets and prorated for the remainder of the quarter. The Firm may also charge a prorated 6 fee for material deposits to an account during a billing period. If you terminate your account during a quarter, a prorated portion of the quarterly fees billed in advance will be refunded to you or if billed in arrears you will be billed for the pro-rata portion of the fee for the period your account was managed by Oak Ridge during the quarter. Typically, the refunds are issued after the end of the quarter or when a Sponsor provides required information to Oak Ridge, but if a client wants the refund earlier a client can request it of Oak Ridge or their Sponsor. Some clients and programs prefer to be billed in arrears based upon the account’s value at the end of the quarter or other relevant period (including in some cases monthly) and, depending on the circumstances, the Firm is amenable to those billing arrangements. The Oak Ridge fees do not include custodial fees, transaction fees, commissions, trading markups or mark-downs, wire fees or any other fees that may be charged by brokers for execution of trades or by custodians for holding and administering the assets in your account. For additional information about brokerage and related expenses, see Item 12, Brokerage Practices. There are instances where, for best execution purposes, Oak Ridge will trade accounts, in particular for smaller or less liquid stocks, at a firm other than the Sponsor, even for wrap accounts. This may result in a transaction charge for that trade that is not covered by the wrap fee and clients would be paying that charge (see Item 12, Brokerage Practices). If your account holds mutual funds, including money market funds and ETFs, those funds will pay their own additional fees to their service providers. These fees will not be paid by the wrap sponsor and are in addition to the investment advisory fees charged by Oak Ridge and the Sponsor. Further information about fees paid by mutual funds, money market funds and ETFs in your account can be found in each third-party fund’s prospectus. Oak Ridge does not hold mutual funds in its separately managed accounts and only holds ETFs in those accounts in very limited circumstances upon request by a client, generally limited to a period of time during a tax loss sale waiting period. Sponsored Programs If Oak Ridge manages your money through a Sponsored Program, including wrap fee separately managed account programs and UMAs, and you do not negotiate the fee directly with Oak Ridge, Oak Ridge’s investment management fees are negotiated between Oak Ridge and the Sponsor. Oak Ridge receives its fees directly from the Sponsor as a portion of the fee the Sponsor charges you for the Sponsored Program or UMA. You should consult the Sponsor’s Form ADV Part 2A (Brochure) or Wrap Brochure, as applicable, for additional information on the fees charged, billing practices and other charges related to that account. ERISA Account Fees and Compensation Oak Ridge acknowledges that it is a fiduciary for assets in client accounts for employee benefit plans governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The information below is provided to comply with the disclosure requirements of ERISA Section 408(b)(2). The information summarizes the direct and indirect compensation that 7 Oak Ridge reasonably expects to receive in connection with providing investment advisory services to employee benefit plans subject to ERISA. Direct Compensation – For clients who have a contract directly with Oak Ridge, the Firm receives an investment management fee which is billed to the plan fiduciary. This fee may be paid from the plan assets or by the plan sponsor or beneficiary, in accordance with the plan documents. The fee is based on the assets in the account and is set forth in the fee schedule of the agreement between the client and Oak Ridge. Upon request, Oak Ridge can provide details on the direct compensation paid to the Firm and such amounts are generally reflected on client account statements and reports from your custodian. Indirect Compensation – Employee benefit plans that utilize Oak Ridge’s services through a Sponsored Program may pay fees to the Sponsor and not directly to the Firm. In those cases, the Sponsor pays a portion of its fees to Oak Ridge, as described more fully above and in the Sponsor’s Form ADV or Wrap Brochure. Oak Ridge may recognize an indirect benefit in the form of research and execution services acquired through trading with or payment of soft dollars (trade commissions or markups/mark-downs on trades) to research service providers. Proprietary research generally includes access to conferences, analysis, forecasts and in-house research. These services do not have an identifiable monetary value. To the extent Oak Ridge were to use other services, such as third-party research services paid for by a broker, an estimated allocation of monetary value can usually be made. Additional information about Oak Ridge’s use of soft dollar services can be found in Item 12, Brokerage Practices. Item 6 Performance-Based Fees and Side-by-Side Management Oak Ridge does not charge any performance-based fees to clients invested in the Equity Strategies, or any other client at this time. Item 7 Types of Clients Our clients consist of individuals, pension and profit-sharing plans, retirement accounts, trusts, estates, corporations and other business entities, charitable organizations, and banks and thrift institutions. Clients can access our portfolio management by opening an account directly with us (with custody to be at a brokerage firm), with a Sponsor in a program we sub-advise or in a UMA program. All accounts, other than UMA accounts, are discretionary, which means that Oak Ridge has been granted the ability to make and implement, and Oak Ridge makes and implements, investment decisions without consulting with the client. 8 The minimum account size for direct separately managed accounts is listed as $1 million, although that is negotiable based on expected growth, total relationship size and other factors. As a result of negotiation, account sizes are usually lower than that amount. Wrap fee and UMA stated program minimums vary and are generally lower than Oak Ridge’s minimum and are often as low as $100,000. They are negotiated between the Sponsor and Oak Ridge or set by the Sponsor’s program. Details on the minimum account sizes for those programs can be found in the respective Sponsor’s Form ADV. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our portfolio managers and analysts focus predominantly on fundamental research in selecting stocks for our clients. We perform bottom-up analysis of companies to evaluate if they meet our investment criteria and we consider cyclical and other factors to in part determine sector and industry weightings. The Equity Strategies invest in common stocks that are traded on United States securities exchanges. Most stocks we purchase are based in the United States, but we may invest a portion of the accounts in stocks or more likely ADRs (American Depository Receipts) of non-U.S. based companies which trade on a United States securities exchange. We believe earnings growth, teamed with strong fundamentals and reasonable valuations, are the primary determinant of long-term stock price appreciation. Stocks are purchased using a long-term horizon and as a result, our annual portfolio turnover tends to be somewhat lower than many other actively managed equity portfolios. The initial position weight is usually 2.5% or less, except for Dividend Growth which is more concentrated. Sector weights in the Equity Strategies may be as high as twice the sector benchmark weight of a larger sector and may be as low as 0% in certain smaller sectors. Key Risks Investing in securities involves risk of loss that clients should be prepared to bear. Past performance is not a guarantee of future results. In addition to the general risks of investing in the stock market, our portfolios bear additional risk. We note that buying a portfolio of securities is usually thought to reduce the risk of buying one or only a few stocks. The description below is an overview of the risks entailed in Oak Ridge’s investment strategies and is not intended to be complete. All investing involves the risk of loss and the investment strategy offered by Oak Ridge could lose money over short or long periods. Performance could be hurt by a number of different market risks including but not limited to: Equity Risk. (All strategies) The value of equity securities may fall due to general market and economic conditions, perceptions regarding the industries in which the issuers participate, or factors relating to specific companies. Equity investments are volatile and will increase or decrease in value based upon issuer, economic, market and other factors. Small capitalization stocks generally involve higher risks in some respects than do investments in stocks of larger companies and may be more volatile. 9 Small & Medium Cap Company Risk. (Small/Mid Cap Growth, All Cap Growth) Smaller companies may be subject to more abrupt or erratic market movements and may have lower trading volumes or more erratic trading than larger, well-established companies. Securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Large Cap Company Risk. (Large Cap Growth, All Cap Growth, Dividend Growth) Larger, more established companies may be unable to attain the high growth rates of successful, small companies during periods of economic expansion. Foreign Investment Risk. (All strategies) Prices of foreign securities (including ADRs) may be more volatile compared to U.S. securities due to economic and social conditions abroad, political developments, and changes in regulatory environments. They are more likely to be subject to currency fluctuation risks. Some of the same considerations apply for U.S. based businesses with significant operations abroad. The securities of non-U.S. issuers also involve a high degree of risk because of, among other factors, the lack of public information with respect to such issuers, less governmental regulation of stock exchanges and issuers of securities traded on such exchanges and the absence of uniform accounting, auditing and financial reporting standards. The non-U.S. domicile of such issuers and currency fluctuations may also be factors in the assessment of financial risk to the investor. Foreign securities markets are often less liquid than U.S. securities markets, which may make the disposition of non-U.S. securities more difficult. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Sector Concentration Risk. (All strategies) We may overweight certain sectors making the portfolios more susceptible to negative events affecting those sectors. Management and Strategy Risk. (All strategies) Investment strategies used by the Firm may not be successful. Portfolio management decisions require judgment and are based on imperfect information. Fundamental Analysis. The Firm utilizes an investment process based upon fundamental business and credit analysis; capital structure and liquidation analysis, a review of all legal documentation surrounding an issuer’s securities and identification of an investment catalyst. In making its investment decisions, the Firm will rely on internally generated research, derived from annual reports, prospectuses, filings with the SEC, corporate press releases, inspections of corporate activities, conversations with the firm and/or competitors, financial newspapers, magazines and other sources. The Firm may also use research materials prepared by others in 10 making an investment decision. During the research process, the Firm makes an assessment of the quality of the security in question by examining among other things financial metrics of the relevant company, the integrity and strategic vision of the management team and the ability to execute such strategy, as well as the attractiveness and risks of the company’s industry. The Firm then determines what is believed to be a fair valuation for the security based on a combination of its future earnings, operating cash flow, free cash flow, liquidation value and revenues. If the public market price for the security is significantly below its fair valuation, the Firm may attempt to purchase the security for a client’s portfolio. If the security is deemed to be priced significantly above its fair valuation and it is currently included in a client’s portfolio, the Firm will generally sell some or all of the position in the security. Performing this combined qualitative and quantitative approach to stock selection encompass the majority of the Firm’s daily activity. Market Risk. The success of Client portfolio activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, commodity prices, economic uncertainty, changes in laws, trade barrier, currency fluctuations and controls, and national and international political circumstances. These factors may affect the level of volatility of securities prices and the liquidity of investments in Client portfolios. Such volatility or illiquidity could impair profitability or result in losses. Cash Management Risks. The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Environmental, Social and Governance Matters. While environmental, social or governance (“ESG”) is only one of the many factors the Firm will consider in making an investment, there is no guarantee that the Firm will successfully implement and make investments in companies that create positive ESG impact while enhancing long-term shareholder value and achieving financial returns. To the extent that the Firm engages with companies on ESG-related practices and potential enhancements thereto, such engagements may not achieve the desired financial and social results, or the market or society may not view any such changes as desirable. Successful engagement efforts on the part of the Firm will depend on the Firm’s skill in properly identifying and analyzing material ESG and other factors and their impact-related value, and there can be no assurance that the strategy or techniques employed will be successful. Considering ESG qualities when evaluating an investment may result in the selection or exclusion of certain investments based on the Firm’s view of certain ESG-related and other factors, and carries the risk that the Firm may underperform funds that do not take ESG-related factors into account because the market may ultimately have a different view of a particular company’s performance than that anticipated by the Adviser. Consideration of ESG factors may affect the Firm’s exposure to certain companies, sectors, regions, countries or types of investments, which could negatively impact the Firm’s performance depending on whether such investments are in or out of favor. Applying impact investing goals to investment decisions is qualitative and subjective by nature, and there is no guarantee that the criteria utilized by the Firm or any judgment exercised by the Firm will 11 reflect the beliefs or values of any particular investor. In evaluating a company, the Firm is dependent upon information and data obtained through voluntary or third-party reporting that may be incomplete, inaccurate or unavailable, which could cause the Firm to incorrectly assess a company’s ESG practices and/or related risks and opportunities. ESG-related practices differ by region, industry and issue and are evolving accordingly, and a company’s ESG-related practices or the Firm’s assessment of such practices may change over time. Further, ESG practices are evolving rapidly and there are different principles, frameworks, methodologies, and tracking tools being implemented by other asset managers, and the Firm’s adoption and adherence to various such principles, frameworks, methodologies and tools is expected to vary over time. There is also a growing regulatory interest across jurisdictions in improving transparency regarding the definition, measurement and disclosure of ESG factors. The Firm’s ESG policies could become subject to additional regulation in the future, and the Firm cannot guarantee that its current approach will meet future regulatory requirements. General Risk of Loss. Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. Risk of Infectious Diseases and Pandemics. Any spread of an infectious illness, public health threat, or similar issue could reduce consumer demand or economic output, result in market closures, travel restrictions or quarantines, social unrest, significant volatility in financial markets, commercial disruption on a global scale and generally have a significant impact on the economies of the affected country and other countries with which it does business, which in turn could cause financial market disruptions and adversely affect clients’ investments in that country and other affected countries. Portfolio Turnover Risk. Portfolio turnover refers to the rate at which investments are replaced. The higher the rate, the higher the transactional and brokerage costs associated with the turnover which may reduce the return, unless the securities traded can be bought and sold without corresponding commission costs. Active trading of securities may also increase your realized capital gains or losses, which may affect the taxes you pay. Cybersecurity and Disaster Recovery Risk. With the increased use of technologies such as the Internet and the dependence on computer systems to perform necessary business functions, Oak Ridge, and its service providers may be susceptible to operational, information security and related risks. These systems are subject to a number of different threats or risks that could adversely affect the clients and their accounts, despite the efforts of the Firm and service providers to adopt technologies, processes and practices intended to mitigate these risks and protect the security of their computer systems, software, networks and other technology assets, as well as the confidentiality, integrity and availability of information belonging to the clients and the investors. In general, cyber incidents can result from deliberate attacks or unintentional events. Unintentional events may have similar effects. The risks associated with unintentional acts include power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information, stealing or corrupting data, or causing operational disruption. Cyber-attacks may also be carried out in a manner that does not require 12 laws, regulatory fines, penalties, financial gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Third parties may also attempt to fraudulently induce employees, customers, third-party service providers or other users of Oak Ridge’s systems to disclose sensitive information in order to gain access to Oak Ridge’s data or that of the client. Cyber incidents affecting Oak Ridge and its respective service providers have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, impediments to trading, fraudulent trading and transfer activity, cause information and technology systems to become inoperable for extended periods of time or to cease to function properly, the inability to transact business, violations of applicable privacy and other losses, reputational damage, reimbursement or other compensation costs, or additional compliance costs. There is also a risk that cybersecurity breaches may not be detected. The information and technology systems of Oak Ridge and its service providers may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches (e.g., “hacking” or malicious software coding), The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in Oak Ridge and/or service providers operations, potentially resulting in financial losses, the inability to transact business, or a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information relating to clients. Such a failure could harm to the Firm’s reputation, subject any such entity and their respective affiliates to legal claims and otherwise affect their business and financial performance. While the Firm and its service providers have established business, continuity plans in the event of, and risk management systems to prevent or reduce the impact of cyber-attacks, there are inherent limitations in such plans and systems due in part to the ever-changing nature of technology and cyber security attack tactics, including the possibility that certain risks have not been identified and prepared for. Furthermore, Oak Ridge cannot control the cyber security and business continuity plans and systems put in place by service providers or any other third parties whose operations may affect our clients and could be negatively impacted as a result. Although Oak Ridge and all of its service providers have implemented various measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, the relevant party may have to make a significant investment to fix or replace them. Item 9 Disciplinary Information Investment advisers are required to report material facts regarding legal or disciplinary events that are material to a client’s evaluation of the firm. Oak Ridge has nothing to disclose under this item. 13 Item 10 Other Financial Industry Activities and Affiliations Oak Ridge has relationships and arrangements with other financial industry entities that could create a conflict of interest or are material to Oak Ridge’s business. North Square Investments, LLC (“NSI”) Certain former employees of Oak Ridge joined a new investment advisory company in 2018, NSI. NSI employees provide certain marketing services to Oak Ridge. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Oak Ridge has adopted a Code of Ethics (the “Code”) to address potential conflicts of interest between personal conduct and fiduciary duty to our clients. All employees must read, understand and acknowledge the terms of the Code at least annually. A copy of the Code is available upon request by contacting us at 312-857-1040. Our goal is to make employees aware that they have an ongoing duty of good faith to act in the best interests of our clients in managing our clients’ accounts; that employees’ personal securities transactions must be conducted consistent with the Code in a way that avoids or mitigates any conflict of interest; and that no inappropriate advantage should be taken of any position of trust or responsibility given to us by our clients. The Firm’s employees are required to follow the Code of Ethics. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of the Firm will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. The Firm permits its supervised persons to engage in personal securities transactions. Personal securities transactions by employees may raise potential conflicts of interests when such person’s trade in a security that is owned or considered for purchase or sale by a client. Subject to satisfying the provisions of the Code and applicable laws, officers, directors and employees of the Firm and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Firm clients. Firm employees may take investment actions that differ from the advice given or the timing or nature of action with respect to any one client account. Subject to the aforementioned restrictions, the Firm and its supervised persons may at any time hold, acquire, increase, decrease, dispose of, or otherwise deal with positions in investments in which a client account may have an interest from time to time. Where the Firm or a supervised person is contemplating taking a position in a recommended security, the Firm or its supervised persons will refrain from engaging in any security 14 transaction inconsistent with the Code and fiduciary responsibility to the Firm’s clients. Neither the Firm nor any supervised person will affect the market in a security the Firm recommends that a client buy or sell. Oak Ridge employees, for their own accounts, accounts of family members and other accounts where employees have discretion to trade, are required to pre-clear most personal securities transactions. Pre-clearance will not be granted when a strategy trade (one which is done across the board in an Equity Strategy) is being actively considered or is in progress. Notwithstanding the previous sentence, employees who have accounts that are managed by Oak Ridge in an Equity Strategy (in a manner similar to other accounts in that strategy) will participate in trading along with other accounts in that strategy. Client accounts do not hold mutual funds other than money market funds and in very limited situations ETFs as described earlier. One or more employees may manage securities portfolios for friends and family members, including acting as trustee for trusts established by those friends and family members. These portfolios: a) are clients of Oak Ridge which trade alongside other client accounts; or b) are not clients or traded in the same strategies that Oak Ridge uses for client accounts. Employees are not paid advisory fees by the trusts or individuals for managing these accounts, except that they may receive trustee fees for serving as trustee for the account, and these accounts are disclosed and subject to Oak Ridge’s personal securities transactions policies and Code of Ethics. All employee trading is reviewed by compliance and is monitored on an ongoing basis for conflicts of interest. Item 12 Brokerage Practices Oak Ridge’s policy is to seek to obtain best execution, the best combination of net price and execution while considering potentially certain other factors such as research made available for the benefit of our clients as a result of trading, for our clients. When deciding what brokers to use, the Firm evaluates the full range and quality of services including quality of execution, research and related services provided, financial stability, responsiveness, clearance and settlement procedures, and other factors. Oak Ridge also may choose firms through which to execute client trading due to client instructions (directed brokerage) or to compensate a brokerage firm or vendor for research and related services directly or indirectly provided to us (soft dollars) as described below. Directed Brokerage The majority of our clients access Oak Ridge’s services through Sponsored Programs. The majority of these programs require or recommend that trading be directed through a specific broker-dealer, often affiliated with the Sponsored Program. In many cases, such as wrap fee programs, the client pays a single fee that includes the Sponsor’s trading costs. Clients who do 15 not participate in Sponsored Programs may also have a relationship with a specific brokerage firm and may choose to direct Oak Ridge to trade through that firm. When Oak Ridge is directed to use a specific brokerage firm, that direction may affect our ability to achieve best execution for a client. For example, the commissions negotiated between a client and the brokerage firm may be higher than what Oak Ridge might have negotiated. The client may be getting other services from the brokerage firm that justify a higher trade cost and Oak Ridge will not negotiate the commission rate for those accounts since the trading location is requested by the client. Some directed brokers charge a minimum commission or a ticket charge for each trade. Although Oak Ridge tries to monitor those situations to avoid excessive fees for client trading, those charges may adversely affect portfolio performance. There may be other advantages Oak Ridge sees in trading with certain firms, including their familiarity with the market for certain stocks or access to blocks of shares in a stock. Oak Ridge may try to mitigate some of the costs associated with directed brokerage when doing trades for large blocks of accounts. See “Trade Aggregation & Rotation” below. Nevertheless, clients who direct Oak Ridge to use a specific broker may in some cases pay a higher commission than other clients and may lose the ability to be aggregated with other clients for trade execution. If the trading is directed by the client back to a broker who has referred the client or other clients to Oak Ridge, we could have a conflict of interest between obtaining the best execution for the client and receiving future referrals from the broker. However, client referrals are not a factor Oak Ridge considers in directing brokerage transactions. A client’s direction as to where to trade the client’s account would often be to the Sponsor of the wrap or other Program in which the client was participating. Oak Ridge’s utilizing that broker would be because the client requested it or because it was economical or logical, not because of potential client referrals. When a client directs Oak Ridge to generally use a particular broker, in certain circumstances Oak Ridge will still trade with a different brokerage firm and “step out” the trade to the directed broker (see below). All clients, including those in wrap fee programs, will pay commissions (references to commissions throughout include price mark-ups and mark-downs) on these trades. Oak Ridge believes that the benefits of the trade aggregation can in certain circumstances, especially prevalent with many (but not exclusively) smaller capitalization stocks, exceed the resultant additional costs and are consistent with our goal of seeking best execution for these clients. Trade Aggregation & Rotation When a portfolio manager initiates a strategy trade (a trade in a security across all accounts in one or more Equity Strategies), orders for multiple accounts may be aggregated and traded in one or more blocks. Accounts where Oak Ridge has trading discretion will be “blocked” together with some directed brokerage accounts. A single broker-dealer will execute a full block but will “step out” a portion or portions of the resultant trade in favor of one or more different broker-dealers that have arrangements with a client(s) or a broker or party who provides research or related services to Oak Ridge. Block trading allows accounts to participate in larger block transactions and get the same execution price, among other potential benefits. 16 Oak Ridge may also block or aggregate rebalancing or other account-specific trades when multiple accounts are traded with a single broker at the same time, but account-specific trades will not be stepped out. Some firms do not allow Oak Ridge to step out transactions for clients. In those cases, we will always use the directed brokerage firm to execute transactions for clients who have directed us to use that firm. In addition, Oak Ridge may use its discretion to exclude brokers from step out trades even if they may be allowed to participate. Reasons for excluding a firm from step out transactions include lack of confidence in the ability to settle the trades properly or efficiently, the size of the overall transaction, and the size of the program or the number of clients in a program, among others. Clients, in particular wrap fee clients, who participate in a transaction that is stepped out, will likely pay charges that they would not otherwise pay. Some firms also charge an additional service charge to process transactions that were traded at other firms. Oak Ridge balances the possibility of clients paying additional fees or commissions with the expectation that a larger block can be traded more efficiently and with market sensitivity that might not be possible when dealing with many smaller trades. Oak Ridge has a trade rotation policy that determines the order in which trades are executed for multiple broker dealers for a strategy trade. The policy is designed to seek to provide an equitable rotation where no broker/client program consistently executes trades earlier or later than others except that if step out blocks are used for a particular trade, and they include multiple brokers, they will usually be traded ahead of directed brokers who do not participate. As a result, priority in the rotation order is often given to accounts and programs where Oak Ridge has more discretion. Accounts with limits on discretionary authority, such as an inability or unwillingness to participate in step outs or Oak Ridge’s lack of visibility into the trading process, may trade in a rotation following the execution of more fully discretionary accounts. - In cases where a block trade is not completed in a single day, trades will generally be allocated pro rata across accounts in the block. For blocks that include multiple Sponsored Programs or directed brokers, the traders may fill programs (or allocate trades pro rata in one or more programs) prior to filling orders for other programs. When determining which programs to complete, we will consider our trade rotation, the size of the order that was completed and other factors including past rotations. Oak Ridge will also take into account programs or accounts that pay minimum commissions or ticket charges and therefore those accounts/programs are more likely to have a random, rather than pro rata, allocation to minimize overall transaction costs to those accounts. Soft Dollars When Oak Ridge has discretion to direct trading, including through aggregating and stepping out trades, the Firm generally will use the commission dollars generated by client transactions to pay for research and related services and execution services. The commissions paid to a brokerage firm - the soft dollars - are paid by only some accounts, but the services that are received in return benefit all clients. Therefore, clients who do not pay those commissions benefit from others’ payments. The Firm also receives a benefit because we are not required to 17 produce or pay directly for the research services that are provided. Oak Ridge may have an incentive to select or recommend a brokerage firm for trades based on our interest in receiving research from that firm rather than strictly considering only that a client is receiving most favorable execution based on other factors alone. As mentioned below, Oak Ridge’s research department, together with its trading department, evaluate as a group the various brokerage firms and other research providers based on the benefits they believe the Firm receives from the trading at the brokerage firm, research availability, research quality, responsiveness to trading requests and other factors. The input of our trading team is important since we believe the efficacy of our trading has an impact on the performance of our investment management and thus indirectly on the success of our Firm. Poor trading results by any brokerage firm over time would result in reduced or eliminated future trading at that firm. The research that Oak Ridge receives from brokerage firms for the benefit of our clients includes invitations to industry conferences, newsletters, access to analysts, one-on-one meetings with company management, and other related items. Oak Ridge also uses some client commissions to pay for research services provided by third-party providers, including in-depth, industry-specific research. However, use of commissions is limited to research services. Certain very limited execution services for Oak Ridge trades for clients may effectively be provided to Oak Ridge due to client trading. For example, this could include software that provides direct access to a broker’s trading desk for quicker and easier order entry and/or trade allocation which can help execution speed and communication. Compensating firms for the value of these services may cause clients to pay more for actual trade execution than they would otherwise, but commissions will generally be within a competitive range for the type of transaction being completed and Oak Ridge believes this is helpful in more effectively completing orders. Brokerage firms that provide soft dollar services are regularly reviewed by Oak Ridge. The Chief Investment Officer, Head Trader and members of the Investment Team evaluate, among other things, the execution services received, the quality of the research related services provided, the breadth of coverage relative to Oak Ridge’s holdings, and responsiveness to our calls. The third-party vendors are also reviewed for the value of the research services procured for the benefit of our clients relative to the commissions that are used to pay for them. Allocation targets for each brokerage firm and third-party vendor are determined based on these inputs. Oak Ridge also compensates brokerage firms for research through commission sharing arrangements. In those cases, Oak Ridge does not trade directly with a research firm but will use another firm to execute trades and that executing firm will use commissions to compensate the research firms. 18 Item 13 Review of Accounts Internal Account Reviews Oak Ridge employees are primarily focused on performing research, portfolio management and trading. Oak Ridge receives some operational support from SEI, a third-party provider. All investment/trading determinations are made by Oak Ridge investment/trading personnel. Accounts are reviewed regularly on a formal basis and periodically on an ad hoc basis. SEI reconciles accounts with custodial records and reviews cash levels on behalf of Oak Ridge, per Oak Ridge standards. For most accounts, reconciliation is done on a daily basis. If daily download information is not available, the reconciliation will occur at least monthly. Oak Ridge’s investment team meets formally at least weekly to discuss portfolio holdings and product sector weightings. Informal meetings occur on a more frequent basis. Dispersion of account performance for accounts within each product is examined at least quarterly. Outlier accounts are identified and the reasons for dispersion are investigated. Client Reporting For clients with an investment advisory agreement directly with Oak Ridge, we send out quarterly reports which include a market commentary and portfolio performance summary. Clients may opt out of receiving statements and/or commentary letters from us by making a written request either directly or through their consultant/broker. In addition, and as their primary source of reporting, all clients receive statements usually monthly but at least quarterly from their custodians with details on transactions. Sponsored Program clients will also be provided with additional information about Oak Ridge’s performance and holdings from the Program Sponsor. Item 14 Client Referrals and Other Compensation Oak Ridge may pay NSI to solicit business for Oak Ridge. NSI currently provides some marketing services for Oak Ridge, including non-exclusive sales representation for its current SMA products and services. NSI is paid by Oak Ridge for sales of these Oak Ridge strategies, governed by a solicitation agreement. NSI employees provide certain marketing services to Oak Ridge. Under a services agreement, NSI carries out activities with respect to Oak Ridge’s marketing and advertising communications efforts. Under Rule 206(4)-1 of the Advisers Act, NSI is considered to be providing an “endorsement” of Oak Ridge’s advisory services in providing these communications. NSI is not a client of Oak Ridge. Due to NSI’s indirect minority ownership interest in Oak Ridge, NSI has a financial incentive to promote Oak Ridge’s services. Any financial incentive creates a conflict of interest. NSI’s communications should be considered in light of this and may not be representative of others’ experience with Oak Ridge. 19 Item 15 Custody Although Oak Ridge does not take physical possession of client funds or securities, Oak Ridge is deemed to have custody of some client assets under the SEC’s Custody Rule only because it deducts fees from certain client accounts, as described below. Oak Ridge provides investment management services only and the physical safekeeping of client assets is performed by qualified custodians (i.e., regulated financial institutions including banks and broker dealers). Advisory Fees For some accounts, Oak Ridge sends an invoice for investment advisory services directly to the qualified custodian or provides notice to the custodian to debit the account for fee payments. In those cases, Oak Ridge is likely deemed to have custody because the client does not specifically direct the payment of the invoices each time, although they provide authority to Oak Ridge and their custodian to perform this task. Usually monthly, but at least quarterly, the custodian sends statements to the client which show, among other things, the advisory fees paid to Oak Ridge. We encourage our clients to review those statements and, if they also receive statements directly from us, to compare the account statements that they receive. In addition, for some of our clients we are authorized to deduct our quarterly investment management fees directly from those clients’ accounts. For this reason alone, this is considered to be custody of those clients’ assets since we have been given the authority and ability to remove fees from the accounts. We have procedures to monitor that we only remove the fees owed to us from those clients’ accounts. As stated above, if we have that ability to remove fees from your account, you should carefully review your statements to monitor that the fee amount we remove is correct and especially that we do not remove more than the fees due us. Service as Trustee/Executor In certain instances, an Oak Ridge employee may serve as the trustee of a trust or executor of an estate for whom we provide advisory services. In order to avoid being deemed to have custody, we limit these situations to those where the employee had a pre-existing relationship (long-time friend or family member) with the decedent, trust grantor or beneficiary. All new relationships of this type are reviewed by Compliance. Item 16 Investment Discretion We accept discretionary authority to manage separately managed accounts which is generally granted in the investment advisory agreement and allows Oak Ridge to determine the identity and amount of the securities to be bought or sold in accordance with each client’s investment objectives. For some Sponsored Programs, discretionary authority is granted to the Sponsor who then delegates that authority to Oak Ridge for certain accounts. 20 As part of our account evaluation and acceptance process, we review any proposed account restrictions desired by the client for the account. Each client has the ability to request in writing that we adhere to certain restrictions and Oak Ridge will review those to determine if they can be implemented effectively. Client-imposed restrictions may affect the ability to manage according to the stated investment strategy, achieve the stated investment goals and may cause deviation from other accounts managed in the same strategy. If the Firm determines that based on the nature or the extent of the requested restrictions we cannot effectively implement those restrictions or that the client would not receive sufficient value due to the restrictions, we decline to manage the account. We will also work with clients on restrictions if the client desires their account be managed in a socially responsible way, as the client may want to define that. Oak Ridge will also provide input on managing an account, if requested, in accordance with environmental, social and governance standards (“ESG”) as the client may want to define or design that. For a portion of our advisory business we provide investment advisory services to certain UMAs managed by broker-dealers or other investment advisers that use in part stock selection information provided by Oak Ridge via a model. We provide the information on our stock selections to the UMA firms as necessary, but usually we are not responsible for deciding whether to implement trades or all of the trades for these accounts and as such these are not considered managed on a discretionary basis. The decision on whether and to what extent to use the information provided by Oak Ridge is left, in varying degrees, to the brokerage/advisory firms. Certain UMA firms will evaluate all of a client’s accounts in their program, including that account or portion of an account using our model information, in determining whether to implement changes suggested by us. We are not the Sponsor of any UMA accounts and the terms of those accounts, including the fees charged to clients by the Sponsors of those accounts, are not determined by us. You should consult with your advisors about any UMA program terms that apply to your account. Item 17 Voting Client Securities Oak Ridge will accept responsibility to vote proxies for securities which are held in client accounts which we manage when our clients direct us to do so. Our authority to vote proxies is established in our investment advisory agreement or the agreement completed with a Program Sponsor. Oak Ridge will vote alike for all shares of a company held by client accounts. We will not accept direction from clients on specific votes except in extraordinary circumstances. We have adopted policies and procedures designed to help us vote in what we believe are our clients’ best interests with a focus on maximizing the economic benefit of owning the shares. Our basic policies and procedures for administering proxy voting are summarized below and a copy of our proxy voting policies and procedures is available by contacting us. 21 We currently use the input of an outside voting advisory service which provides information on proxy ballot issues. While that service provides us with analysis and advice, we make our own voting decisions based upon our voting policies and procedures. We consider the quality of a company’s management to be an important factor in our decision to invest and stay invested in a company. Therefore, we typically vote with company management for routine proposals that do not change the company’s structure, bylaws, or operations in a way we believe is detrimental to shareholders. For Board membership, we will usually vote for individuals nominated in an uncontested election unless we are concerned about issues that would impede the Board member's ability to perform effectively, such as unusual conflicts of interest or membership on too many boards. We typically vote against proposals we believe restrict shareholders' ability to realize the full potential financial value of their stock investment. These include poison pills, supermajority voting requirements, and classified boards. For non-routine matters we evaluate the issues on a case-by-case basis using the same economic focus described above. A conflict of interest may arise where Oak Ridge has discretion to vote proxies for a company that in an uncommon situation has a material business relationship with us or our employees. For matters that are covered by our policies, we will generally vote according to those policies. If the policies do not clearly inform our vote, we may: • choose to vote the proxy in accordance with the voting recommendation of a nonaffiliated third party, such as our outside advisory service, • accept direction from the client(s) or a fiduciary of the client(s), or • abstain from voting. The method we select will depend upon the facts and circumstances of each situation and the requirements of applicable law. We will not vote proxies in certain situations where we determine that the cost of voting a particular proxy exceeds any anticipated benefit to the client or in the event where the exercise of voting rights could restrict the ability of the portfolio manager to freely trade the security. Oak Ridge will not vote proxies for holdings in client accounts which were not purchased based on the firm’s discretionary authority. Information on how we voted proxies for client accounts is available upon request. Class Actions From time to time, Oak Ridge may receive notice of class action suits involving securities held or previously held in client accounts. The Firm does not take any action or provide any legal advice related to these matters. Upon client request, we may be able to assist in providing transaction or holding information necessary for another party to respond to these notices. 22 Item 18 Financial Information Oak Ridge believes it does not have any financial commitments, policies or impairments that require disclosure in response to this item. 23 Additional Information – Privacy Notice FACTS WHAT DOES Oak Ridge Investments, LLC DO WITH YOUR PERSONAL INFORMATION? WHY? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. This information can include: WHAT? Investment experience and transaction history  Social Security number and income  Account balances and account transactions  When you are no longer our customer, we continue to share your information as described in this notice. How? All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Oak Ridge Investments, LLC chooses to share; and whether you can limit this sharing. Does Oak Ridge Investments share? Can you limit this sharing? Reasons we can share your personal information Yes No For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No For our marketing purposes – to offer our products and services to you Yes No Joint marketing with unrelated financial companies N/A N/A For our affiliates' everyday business purposes – information about your transactions and experiences N/A N/A For our affiliates' everyday business purposes – information about your creditworthiness No No For non-affiliates to market to you or go to www.oakridgeinvest.com Questions? Call 312-857-1040 24 Page 2 What we do does Oak Ridge protect my How Investments personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We collect your personal information, for example, when you  Seek financial or tax advice or seek advice about your does Oak Ridge collect my investments How Investments personal information?  Provide account information or make deposits  Enter into an investment advisory contract Federal law aw gives you the right to limit only: Why can't I limit all sharing?  sharing for affiliates' everyday business purposes— information about your creditworthiness  affiliates from using your information to market to you  sharing for non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. Definitions Companies related by common ownership or active control. They can be financial and nonfinancial companies. Affiliates  Oak Ridge Investments has no such affiliates. Companies not related by common ownership or control. They can be financial and nonfinancial companies. Non-affiliates  Oak Ridge Investments, LLC currently only shares with a company named North Square Investments, LLC which is a minority owner of Oak Ridge Investments, LLC. Otherwise, Oak Ridge does not share with non- affiliates so they can market to you. A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Joint marketing  Oak Ridge Investments, LLC may jointly market with North Square Investments, LLC. March 2025 David M. Klaskin Chief Executive Officer, Chief Investment Officer Oak Ridge Investments, LLC 10 South LaSalle St., Suite 2130 Chicago, Illinois 60603 312-857-1040 This brochure supplement provides information about David M. Klaskin that supplements the Oak Ridge Investments, LLC brochure. You should have received a copy of that brochure. Please contact the Oak Ridge Compliance Department using the above contact information if you did not receive Oak Ridge’s brochure or if you have any questions about the contents of this supplement. information about Mr. Klaskin is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Item 2 – Educational Background and Business Experience Business Experience: Mr. Klaskin founded the Firm in 1989 and has served as Chief Executive Officer, Chief Investment Officer and Board member of Oak Ridge. He also served as Chairman from March 2005 through September 2013. He is the senior portfolio manager for the Firm’s Small/Mid Cap Growth, Large Cap Growth and Dividend Growth strategies. Year of birth: 1960 Education: Indiana University, B.S. Item 3 – Disciplinary Information Oak Ridge is required to disclose all material facts regarding certain legal or disciplinary events that are material to an evaluation of Mr. Klaskin. There are no legal or disciplinary events to disclose. Item 4 – Other Business Activities Oak Ridge is required to disclose Mr. Klaskin’s other investment-related business activities and other outside business that is substantial. There are no other business activities to disclose. Item 5 – Additional Compensation Mr. Klaskin does not receive any compensation based on sales, client referrals or new accounts. Nevertheless, as an owner of Oak Ridge, Mr. Klaskin receives an economic benefit based on the overall profitability of the Firm which is indirectly related to sales. Item 6 – Supervision As Chief Investment Officer, Mr. Klaskin has supervisory responsibility for the Firm’s investment process. March 2025 Robert G. McVicker Executive Vice President and Senior Portfolio Manager Oak Ridge Investments, LLC 10 South LaSalle St., Suite 2130 Chicago, Illinois 60603 312-857-1040 This brochure supplement provides information about Robert G. McVicker that supplements the Oak Ridge Investments, LLC brochure. You should have received a copy of that brochure. Please contact the Oak Ridge Compliance Department using the above contact information if you did not receive Oak Ridge’s brochure or if you have any questions about the contents of this supplement. information about Mr. McVicker is available on the SEC’s website at Additional www.adviserinfo.sec.gov. Item 2 – Educational Background and Business Experience Business Experience: Mr. McVicker has been employed by Oak Ridge since its founding in 1989. He is the senior portfolio manager for the All Cap Growth strategy and is a portfolio manager of the Small/Mid Cap Growth and Large Cap Growth strategies. Year of birth: 1965 Education: Ohio State University, B.S. Item 3 – Disciplinary Information Oak Ridge is required to disclose all material facts regarding certain legal or disciplinary events that are material to an evaluation of Mr. McVicker. There are no legal or disciplinary events to disclose. Item 4 – Other Business Activities Oak Ridge is required to disclose Mr. McVicker’s other investment-related business activities and other outside business that is substantial. There are no other business activities to disclose. Item 5 – Additional Compensation Mr. McVicker does not receive any compensation based on sales, client referrals or new accounts. Nevertheless, as an owner of Oak Ridge, Mr. McVicker receives an economic benefit based on the overall profitability of the Firm which is indirectly related to sales. Item 6 – Supervision Mr. McVicker’s investment advice is supervised by David M. Klaskin, Chief Investment Officer of Oak Ridge. Mr. Klaskin can be reached at 312-857-1040. March 2025 Kenneth S. Kailin, CFA Executive Vice President, Senior Portfolio Manager Oak Ridge Investments, LLC 10 South LaSalle St., Suite 2130 Chicago, Illinois 60603 312-857-1040 This brochure supplement provides information about Kenneth S. Kailin that supplements the Oak Ridge Investments, LLC brochure. You should have received a copy of that brochure. Please contact the Oak Ridge Compliance Department using the above contact information if you did not receive Oak Ridge’s brochure or if you have any questions about the contents of this supplement. Item 2 – Educational Background and Business Experience Business Experience: Mr. Kailin has been employed by Oak Ridge since 2002. Prior to that, he was a partner and portfolio manager at Skyline Asset Management. He is the senior portfolio manager for the Mid Cap Growth strategy. Mr. Kailin served as the Chief Compliance Officer of Oak Ridge Investments, LLC from March 2019 to March 2021. Year of birth: 1958 Education: Indiana University, B.S. University of Chicago, MBA Professional Designations: The Chartered Financial Analyst (CFA) charter is a graduate-level investment credential established in 1962 and awarded by the CFA Institute. To earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute as a member; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 – Disciplinary Information Oak Ridge is required to disclose all material facts regarding certain legal or disciplinary events that are material to an evaluation of Mr. Kailin. There are no legal or disciplinary events to disclose. Item 4 – Other Business Activities Oak Ridge is required to disclose Mr. Kailin’s other investment-related business activities and other outside business that is substantial. There are no other business activities to disclose. Item 5 – Additional Compensation Mr. Kailin does not receive any compensation based on sales, client referrals or new accounts. Nevertheless, as an owner of Oak Ridge, Mr. Kailin receives an economic benefit based on the overall profitability of the Firm which is indirectly related to sales. Item 6 – Supervision Mr. Kailin’s investment advice is supervised by David M. Klaskin, Chief Investment Officer of Oak Ridge. Mr. Klaskin can be reached at 312-857-1040. March 2025 Brian L. King, CFA Vice President, Research Analyst and Portfolio Manager Oak Ridge Investments, LLC 10 South LaSalle St., Suite 2130 Chicago, Illinois 60603 312-857-1040 This brochure supplement provides information about Brian L. King that supplements the Oak Ridge Investments, LLC brochure. You should have received a copy of that brochure. Please contact the Oak Ridge Compliance Department using the above contact information if you did not receive Oak Ridge’s brochure or if you have any questions about the contents of this supplement. Item 2 – Educational Background and Business Experience Business Experience: Mr. King has been employed by Oak Ridge since 2006 and is a member of the investment team. Prior to that, he worked for three years at Timeless Investment Management and served as a Lieutenant in the U.S. Navy. He is a portfolio manager of the Mid Cap Growth portfolio and the Dividend Growth portfolio. Year of birth: 1972 Education: United States Naval Academy, BS University of Michigan, MBA Professional Designations: The Chartered Financial Analyst (CFA) charter is a graduate-level investment credential established in 1962 and awarded by the CFA Institute. To earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute as a member; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Item 3 – Disciplinary Information Oak Ridge is required to disclose all material facts regarding certain legal or disciplinary events that are material to an evaluation of Mr. King. There are no legal or disciplinary events to disclose. Item 4 – Other Business Activities Oak Ridge is required to disclose Mr. King’s other investment-related business activities and other outside business that is substantial. There are no other business activities to disclose. Item 5 – Additional Compensation Mr. King does not receive any compensation based on sales, client referrals or new accounts. Nevertheless, as an owner of Oak Ridge, Mr. King receives an economic benefit based on the overall profitability of the Firm which is indirectly related to sales. Item 6 – Supervision Mr. King’s investment advice is supervised by David M. Klaskin, Chief Investment Officer of Oak Ridge. Mr. Klaskin can be reached at 312-857-1040.