ROBOTTI & COMPANY ADVISORS, LLC

Item 1. Cover Page ROBOTTI & COMPANY ADVISORS, LLC Part 2A of Form ADV Firm Brochure 125 Park Avenue, Suite 1607 New York, NY 10017 www.robotti.com Phone: (212) 986-4800 Fax: (212) 986-0816 January 29, 2026 This brochure (the “Brochure”) provides information about the qualifications and business practices of Robotti & Company Advisors, LLC (the “Adviser”). If you have any questions about the contents of this Brochure, please contact us at (212) 986-4800. The information in this Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (the “SEC”) or by any state securities authority. The Adviser is an investment adviser that is registered as such with the SEC under the Investment Advisers Act of 1940. Registration of an investment adviser does not imply any level of skill or training. information about the Adviser also is available on the SEC’s website at Additional www.adviserinfo.sec.gov. i Form ADV, Part 2A Firm Brochure January 29, 2026  Item 2. Material Changes This Brochure contains information about the Adviser, and the separately managed accounts offered by the Adviser and the Adviser’s investment management services for private investment funds formed by its affiliates. A full and complete copy of the ADV Part 2A can be obtained, free of charge, upon request from the Firm. The following material changes have been made since the last annual update to the Adviser’s Brochure on March 28, 2024: Item 5 has been amended to include the fee range for the Select Value Strategy. Please retain a copy of this Brochure for your records. ii Form ADV, Part 2A Firm Brochure January 29, 2026  Item 3. Table of Contents Item Number Page Item 1. Cover Page ........................................................................................................................... i Item 2. Material Changes .................................................................................................................ii Item 3. Table of Contents ............................................................................................................... iii Item 4. Advisory Business ............................................................................................................... 1 Item 5. Fees and Compensation ..................................................................................................... 2 Item 6. Performance-Based Fees and Side-By-Side Management ................................................. 8 Item 7. Types of Clients ................................................................................................................... 9 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 9 Item 9. Disciplinary Information ................................................................................................... 14 Item 10. Other Financial Industry Activities and Affiliations ........................................................ 14 Item 11. Code of Ethics ................................................................................................................. 17 Item 12. Brokerage Practices ........................................................................................................ 19 Item 13. Review of Accounts ........................................................................................................ 23 Item 14. Client Referrals and Other Compensation ..................................................................... 24 Item 15. Custody ........................................................................................................................... 24 Item 16. Investment Discretion .................................................................................................... 25 Item 17. Voting Client Securities................................................................................................... 25 Item 18. Financial Information ..................................................................................................... 26 iii Form ADV, Part 2A Firm Brochure January 29, 2026  Item 4. Advisory Business Background The Adviser is a New York limited liability company. The predecessor firm to the Adviser, Robotti & Company, Incorporated (the “Parent”), was founded by Robert Robotti in 1983 and was registered as a broker-dealer that same year. In 2001, the Parent was registered as an investment adviser. In 2003, the Parent formed the Adviser and Robotti Securities, LLC (“Robotti BD,” which was, until June 2017, named Robotti & Company, LLC). The Adviser succeeded to the investment adviser business of the Parent and Robotti BD succeeded to the broker-dealer business of the Parent, and Parent became a holding company. Robotti BD is a broker-dealer registered under Section 15 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), with the SEC and the Financial Industry Regulatory Authority (“FINRA”). Each of the Adviser and Robotti BD is wholly owned by the Parent. Mr. Robotti is the principal owner of the Parent. Mr. Robotti is the president of the Adviser. Mr. Robotti, born in 1953, graduated from Bucknell University in 1975 with a BS in Accounting. He received his MBA from Pace University in 1978. Investment Management Services The Adviser offers discretionary and non-discretionary investment management services for separately managed accounts on both a non-wrap fee basis (“Managed Accounts”) and a wrap fee-basis (“Wrap Fee Accounts”, which with the Managed Accounts are collectively referred to herein as “Separately Managed Accounts”). The Adviser’s strategies for Managed Accounts are the Value Equity Strategy, Select Value Strategy, Single Issue Strategies and Central Asia Opportunity Strategy. For Wrap Fee Accounts, the Adviser offers two strategies: Value Equity Strategy and Concentrated Value Strategy. These strategies are described below in Item 8 – “Methods of Analysis, Investment Strategies and Risk of Loss.” The Adviser receives a portion of the wrap fee for its services as described below in Item 5 – “Fees and Compensation.” Consultant. An unaffiliated SEC-registered investment adviser and financial planner (the "Consultant") introduces prospective clients to the Adviser for Managed Accounts in the Value Equity Strategy. In these instances, the Consultant performs the analysis and development of the client’s personal investment strategy, and the Adviser is one of several unaffiliated investment managers that the Consultant has selected to be made available to its clients. The Consultant provides information on those investment managers (including the Adviser) to its clients, and the Consultant’s client then chooses the investment managers it desires and determines (with the advice of the Consultant) an allocation to make to the investment manager. Additional Matters The Adviser does not offer financial planning services or an asset allocation program based on 1 Form ADV, Part 2A Firm Brochure January 29, 2026  the client’s financial circumstances. Clients who engage the Adviser should be specifically seeking value strategies for the portion of their investment portfolio committed to the Adviser. Within this context, the Adviser will take into account certain individual needs of clients and will permit clients to impose certain investment policies, guidelines or reasonable restrictions on how the account is managed including restrictions on investing in certain securities or types of securities. Any policy, guideline or restriction by a client may adversely affect investment returns. While the Adviser focuses primarily on U.S. and foreign equity securities, an account may also own one or more of the following: convertible stocks, bonds, warrants, corporate, municipal, or government debt, commercial paper, CDs, mutual funds, exchange traded funds, other investment products and cash and cash equivalents. Finally, the Adviser provides investment management services for customized portfolios of private investment funds formed by its affiliates (the “Robotti Funds”) pursuant to value investing and/or other strategies as described in each fund’s offering documents provided to investors. Assets under Management As of December 31, 2024, the Adviser managed a gross total of $881,805,476 on a discretionary basis and $0 on a non-discretionary basis. Item 5. Fees and Compensation Managed Accounts The Adviser charges either an asset-based management fee or a performance-based incentive fee for its investment advisory services. Managed Accounts – Asset-based Management Fee Managed Account fees (“Management Fees”) are charged as a percentage of the value of a client’s account, as set forth in the client’s account agreement. Generally, the Adviser charges a fee of 1% to 2% per annum of assets under management in the client account. The fee charged for the Select Value Strategy is .90% to 1.20% per annum of assets under management. Fee Computation. Management fees are generally debited quarterly from the client’s Managed Account in an amount equal to one quarter of the contractual annual fee, based on the value of assets under management. For Managed Accounts introduced by it, the Consultant debits the Adviser’s Management Fee from the client’s Managed Account in accordance with client authorization and pays that amount to the Adviser. For the initial quarter in which the Managed Account is opened, the value of the Managed Account on the last business day of such quarter is used to calculate the initial Management Fee which is paid following the end of such quarter. The initial Management Fee is prorated for such portion of the quarter that the Managed Account was open if opened following the beginning of 2 Form ADV, Part 2A Firm Brochure January 29, 2026  a quarter. In the Adviser’s discretion, however, when a Managed Account has been funded in the week preceding a quarter end, there is no Management Fee charged for that week. For each succeeding quarter, the Management Fee is paid to the Adviser in advance based upon the value of the Managed Account on the last business day of the preceding calendar quarter. When the first quarter’s Management Fee is paid in arrears, the first and second quarter Management Fees are paid at the same time and the value of the Managed Account on which the second quarter’s Management Fee is calculated includes the amount payable for the first quarter’s Management Fee. A pro rata refund to the client of prepaid Management Fees shall be made if the Managed Account is closed within a quarter and all of the proceeds or assets are withdrawn by the client. When the Management Fee is paid in advance, no refunds of Management Fees are made with respect to partial withdrawals from a Managed Account and no additional Management Fees are charged for additions to a Managed Account during a quarter. Management Fees are not refunded in the case of a change of trustee or account registration. However, when one or more accounts are closed and the assets thereof are transferred to a new or existing Managed Account with the same Management Fee structure (the client of such new or existing Account, a “Successor Client”), because the Adviser will continue to manage the assets, a new fee will not be charged and a pro rata portion of the Management Fee will not be refunded. This may occur when there is (i) a change in the account strategy, (ii) a change in the account registration or title, (iii) a new account owner(s), (iv) a new trustee of a trust account or (v) a similar circumstance. When cash and/or securities from a Managed Account are transferred to a new Managed Account with a performance fee structure, the transfer will be treated as a partial withdrawal with no refund of the Management Fee followed by a contribution to the new Managed Account. In general, for purposes of calculating the performance fee, the value of the new Managed Account will be the value of cash plus the net proceeds of the sale of any securities transferred and sold by the Adviser. If the Adviser determines to retain any of the securities transferred, the value of such securities will be the closing value as of the date the performance fee Managed Account receives the securities as valued under the related Advisory Agreement (unless the Advisory Agreement provides for a different methodology for retained securities). Account Valuation. For purposes of calculating the client’s Management Fee, transactions and the value of cash and securities in the client’s Managed Account are computed on a trade date basis. Statements from the client’s custodian will typically reflect transactions as of their settlement date (typically one business day following the trade date for U.S. securities transactions) and may value securities and foreign currencies using different valuations from those on which the Management Fee has been calculated (see next paragraph). Accordingly, there may be a discrepancy between both the positions in the client’s Managed Account and the values of securities and cash used to calculate the Management Fee and the positions and values set forth on the client’s statement from its custodian. For each strategy other than the Select Value Strategy, each security listed on a securities exchange shall be valued at the last quoted sales price during normal trading hours on the 3 Form ADV, Part 2A Firm Brochure January 29, 2026  primary exchange on which such security is traded on the date for which the value is sought. Each security traded in the over-the-counter market shall be valued at the last quoted sales price during normal trading hours in the over-the-counter market on which such security is traded on the date for which the value is sought. If there was no such trade on such valuation date, whether exchange listed or not, securities held long will be valued at the closing bid price and securities held short will be valued at the closing ask price, as reasonably determined by the Adviser. If, however, in the judgment of the Adviser, any price determined under this paragraph relates to a trade or trades that are deemed not to reflect the fair value of a security, such security’s value will be as reasonably determined by the Adviser. Any other security or asset shall be valued in a manner determined in good faith by the Adviser to reflect its fair value. The Adviser reserves the right to accrue for dividends as of the ex-dividend date of any security until the distribution of such dividend. The value in U.S. Dollars of foreign currencies, or securities or other assets denominated in foreign currencies will be based upon the rate of exchange between the U.S. dollar and such foreign currency as of the date for which a value is sought unless industry practice is to use a different date; provided, that in any event the Adviser may reasonably determine to use a different date. For the Select Value Strategy, the Adviser is required to rely on the custodian, Interactive Brokers, for valuing securities for calculating the Management Fee, account statements and transactions. The Adviser values securities for the purpose of calculating its Management Fee for its other strategies. Therefore, there may be slight differences in the values of securities used to calculate the Management Fee under the Select Value Strategy and the values of the same securities as of the same date for the purpose of calculating the Management Fee of the Adviser’s other strategies. Managed Accounts - Performance Fees Certain Managed Accounts will be charged a Performance Fee. The specific terms of each Performance Fee may be different for each Account and are detailed in the Advisory Agreement relating to the Managed Account. Valuations of securities and cash, for purposes of calculating the Performance Fee, are as described above under “Managed Accounts – Asset-based Management Fee – Account Valuation.” Wrap Fee Accounts The Adviser charges a “Wrap Fee” for participation in the Wrap Fee program (“Wrap Fee Program”). The Wrap Fee is an asset-based management fee and is calculated using a percentage of the value of the Wrap Fee Account, as set forth in the client’s Wrap Fee Account agreement and described below. The Wrap Fee percentage rate will not change based on increases or decreases in the value of the client’s Wrap Fee Account or additions to or withdrawals from the Wrap Fee Account absent a written agreement between the Adviser and the client. The Wrap Fee will be generally charged as a percentage of assets under management, as shown below: 4 Form ADV, Part 2A Firm Brochure January 29, 2026  ASSETS $0-$2,499,999 $2.5 million-$4,999,999 $5 million-$9,999,999 $10 million-$14,999,999 $15 million-$24,999,999 $25 million + ANNUAL FEE 2% on all assets 1.75% on all assets 1.50% on all assets 1.25% on all assets 1.10% on all assets 1.00% on all assets The Wrap Fee is calculated (including as to account closures, additions, withdrawals and transfers) and the client’s Wrap Fee Account is valued in the same manner as set forth above in “Managed Accounts – Asset-based Management Fee – Fee Computation” and “Managed Accounts – Asset-based Management Fee – Account Valuation,” respectively. Wrap fees are generally debited quarterly from the client’s Wrap Fee Account in an amount equal to one quarter of the contractual annual fee, based on the value of assets under management. Clients in the Wrap Fee Program will not be charged brokerage commissions for the execution of securities trades. All transaction-based costs, with the exception of wire transfer fees, certificate issue fees, special delivery request fees, reorganization fees, SEC exchange fees, stock transfer taxes, margin interest, custodial fees and similar administrative fees, are included within the Wrap Fee negotiated between the client and the Adviser within the parameters of the fee schedule above. A counterparty markup or markdown or dealer’s spread may be built into the price of over-the-counter or exchange traded securities traded within the Wrap Fee Program. The Adviser, however, will pay any incremental costs if a broker-dealer other than Robotti BD is used for a transaction in the client’s Wrap Fee Account. Wrap Fee Account Fees do not include expenses of any mutual funds or ETFs that are included in the client’s portfolio; however, the Adviser may, at its discretion, absorb some of these additional fees. The Adviser may have incentives not to trade in client Wrap Fee Accounts due to its absorption of these charges and expenses. Moreover, a client may incur higher costs by participating in the Wrap Fee program instead of a Managed Account, for example if the client’s portfolio trades infrequently or has a high cash balance. Accordingly, it may be more cost effective to the client for the account to pay brokerage commissions and other fees rather than pay a higher wrap fee. Wrap Fee Accounts – Performance Fees A client may request that a Wrap Fee Accounts be charged a Performance Fee instead of an asset- based fee. The specific terms of each Performance Fee may be different for each Account and will be detailed in the Advisory Agreement relating to the Wrap Fee Account. Robotti Fund Fees and Expenses The Adviser receives a quarterly Management Fee from some of the Robotti Funds. Such Management Fees range from point one eight seven five of one percent (0.1875%) to three- eighths of one percent (0.375%) of the net asset value of each investor’s interest in the fund and 5 Form ADV, Part 2A Firm Brochure January 29, 2026  is payable in advance on the first business day of each calendar quarter. The interest is valued as set forth in such fund’s offering documents as of the opening of business on the first business day of each calendar quarter. The Management Fee is adjusted on a pro rata basis for any contributions made during the calendar quarter. The Adviser may, in its sole discretion, waive all or any portion of the Management Fee applicable to any investor. While certain Robotti Funds do not charge a Management Fee, the Adviser will receive a fee intended to cover regulatory, compliance and similar fees and expenses relating to such Robotti Funds (the “Regulatory Expense Fee”), payable in advance on the first business day of each calendar quarter, equal to one fortieth of one percent (0.025%) of such Robotti Fund’s net asset value as of the opening of business on the first business day of such calendar quarter. This fee is adjusted on a pro rata basis for any contributions made during the calendar quarter. The Adviser may, in its sole discretion, waive all or any portion of this fee applicable to any investor. In addition, affiliates of the Adviser that act as the managing member or general partner, as applicable, to the Robotti Funds, generally are entitled to a performance allocation equal to twenty percent (20%) of the net profits (or in the case of some funds a different performance allocation, as provided in relevant Robotti Fund documents) allocated to each investor’s capital account in each fund. The performance allocation is generally made at the end of each calendar year and when an investor withdraws from a fund. The performance allocation of net profits from each investor’s capital account is subject to a loss carryforward limitation, so that no performance allocation is made until prior net losses allocated to such investor are recouped. The performance allocation calculation and the loss carryforward limitation are adjusted as necessary to take into account distributions to or withdrawals by an investor. The managing member/general partner may, in its sole discretion, waive all or a portion of the performance allocation to any investor. The managing member/general partner may also allocate a portion of its performance allocation to the Adviser's or Robotti BD's personnel (see below under “Affiliated Solicitor Fees”), to an unaffiliated introducing investment adviser (see below under “Other Fees to Which an Account is Subject -- Consultant’s Fee.) or to an unaffiliated broker-dealer with which the Adviser (or the managing member/general partner) has a placement agreement. With respect to the management and performance fees described above, prospective clients should note that similar advisory services may be available from other registered investment advisers for similar or lower fees. An investor in a Robotti Fund is responsible for the costs and expenses set forth in the relevant Robotti Fund’s offering documents, including any applicable Management Fee, Regulatory Expense Fee and/or performance allocation. Such costs and expenses often include, among others, all reasonable expenses related to the Robotti Fund's continuation, including, but not limited to, legal and accounting fees, government filing fees and printing and mailing expenses, and the expenses of the offering of interests in the Robotti Fund; any reasonable travel, legal, administrator, bookkeeping, accounting and audit fees and expenses (including without limitation any required surprise examinations of it or the Adviser), as well as those associated with investigating potential investments or maximizing return on existing investments; fees and expenses associated with regulatory compliance matters, the annual audit, tax and information 6 Form ADV, Part 2A Firm Brochure January 29, 2026  return preparation, taxes and government filing fees; and all reasonable custodial fees (including fees related to any change of custodian), interest on borrowed funds, transfer taxes, brokerage commissions, fees and expenses for consulting, research and statistical services, any extraordinary expenses such as litigation expenses and any other ongoing operating expenses of the Robotti Fund as determined by the managing member or general partner. Allocations of permitted expenses that relate to a security held by multiple Robotti Funds are generally made based upon the proportionate ownership of the security to which the expense relates. The Robotti Funds have in the past and may from time to time in the future enter into “side letter” or other arrangements with certain Fund investors that may provide for terms of investment that are more favorable than the terms provided to other investors in such Fund, including, without limitation, with respect to fees, expenses, redemption rights and information rights. Other Fees to Which an Account is Subject Consultant’s Fee. For Managed Accounts referred to the Adviser by the Consultant, the Consultant’s fee, normally 1% per annum of the assets under management, is billed along with the Adviser’s Management Fee as described above on a quarterly basis. Fees are debited from the client’s account by the Consultant in accordance with client authorization and are paid to the Consultant, which remits to the Adviser its Management Fee. Neither the Consultant nor the Adviser retains any portion of the fee due to the other party. With respect to investments made by investors referred to the Robotti Funds by the Consultant, a portion of such investor’s management fee and performance allocation will be paid or allocated, as applicable, to the Consultant and/or its affiliate, in each case as payment of investment advisory fees owed by such investor as a client of the Consultant. Brokerage. With the exception of Wrap Fee Accounts, in addition to the Adviser’s advisory fees, clients are also responsible for the brokerage commissions charged by broker dealers, including Robotti BD, the Adviser’s affiliate. Brokerage arrangements are discussed in more detail in Item 12, below. Fees of the Custodian. Fees of the client’s custodian, if any, are separately charged to Separately Managed Accounts by the client’s custodian. Mutual Funds, Money Market Funds and ETFs. To the extent that clients’ accounts are invested in mutual funds, including money market funds, or exchange-traded funds (ETFs), these funds charge a separate layer of management, trading, and administrative expenses payable to the funds’ sponsors, advisers, administrators, and other service providers. Client Fees 7 Form ADV, Part 2A Firm Brochure January 29, 2026  Fees vary among our clients and can be negotiable based upon a number of factors, including, but not limited to, the size of the client’s account, the nature of related services provided, the length of the advisory relationship with a client and the nature of the client. Affiliated Solicitor Fees The Adviser, in some instances, may compensate current portfolio managers, relationship managers or professional staff of the Adviser, Robotti BD or third-party solicitor (together, “Affiliated Solicitors”) for client referrals. Accounts referred by Affiliated Solicitors will be subject to the Adviser’s normal fee schedule, subject to any negotiation with the client; the client will not be charged any additional fees or expenses as a result of the referral. An Affiliated Solicitor may earn a larger fee for recommending a Managed Account with a performance fee or a Robotti Fund, and in some cases, for recommending a Wrap Fee Account, than for a Managed Account subject only to an asset-based management fee. Accordingly, an Affiliated Solicitor has an incentive to recommend such an account or a Robotti Fund over a Managed Account. The Adviser strives to mitigate this conflict by maintaining compliance policies requiring that client funds be placed only in investments fitting their financial situation and investment profile. Conflicts relating to management of performance fee accounts and non-performance fee accounts are described in Item 6 – “Performance-Based Fees and Side-By-Side Management” below. Other Compensation Certain of the Adviser’s employees may receive remuneration, and reimbursement of out-of- pocket expenses, from a portfolio company in connection with serving as a director on the portfolio company’s Board of Directors. Item 6. Performance-Based Fees and Side-By-Side Management The Adviser advises the accounts of Robotti Funds and certain Managed Accounts, which pay the Adviser performance fees, as described above in Item 5. The performance fees paid by these accounts create certain conflicts of interest for the Adviser. First, performance-based fee arrangements create an incentive for the Adviser to favor performance fee paying accounts over other accounts in the allocation of investment opportunities because the Adviser can potentially receive greater fees for the same amount of investment. Second, a performance fee arrangement creates an incentive for the Adviser to make riskier or more speculative investments for accounts subject to performance fees due to the possibility of generating higher returns for the Adviser. In addition, where a fee is based in part on the unrealized appreciation of securities in one year, as is the case with these performance fees, a subsequent decline in the value of the securities can result in loss of unrealized gains or can result in realized losses in a subsequent year on which a performance fee has been paid by the client. The Adviser believes that it mitigates the risks of these conflicts by having policies for the equitable allocation of trades among its investment products and by having clearly defined and differing investment strategies and by having policies for the equitable allocation of trades among its investment products, by placing client funds only in investments fitting to their financial situation and investment profile. 8 Form ADV, Part 2A Firm Brochure January 29, 2026  Item 7. Types of Clients The Adviser offers investment advisory services to, among others, high net worth individuals, pension and profit-sharing plans, trusts, charitable organizations, corporations and other business entities, and private investment funds (i.e., the Robotti Funds). The Adviser requires a minimum account of $500,000 for opening a Separately Managed Account, although the minimum account size may be negotiable under certain circumstances. The Adviser may group certain related client accounts for the purposes of meeting the minimum account size requirement. The Robotti Funds also have minimum investment amounts as set forth in their respective offering documents. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis The Adviser's investment decisions are based on fundamental security analysis, and the main sources of information used by the Adviser are financial newspapers, research materials prepared by third parties, review of corporate filings (e.g., annual reports, prospectuses, filings with the SEC), and technology-based tools (i.e., computer software programs) to analyze the performance of equity and debt securities. The Adviser may use computer software programs provided by third-party advisers in providing this advice to clients. The Adviser’s strategies are focused on long-term capital appreciation. Investment Strategies Value Equity Strategy Mr. Robert Robotti is the Portfolio Manager for the Adviser’s Value Equity Strategy. The strategy focuses primarily on small- to mid-capitalization (“small cap” and “mid cap”) companies that are overlooked, out-of-favor or misunderstood by the market and which the Portfolio Manager believes are undervalued. While small to mid-cap at time of purchase these companies may, through merger and/or growth, become larger cap. The Adviser believes that holding larger cap companies is a natural evolution of its buy-and-hold approach with respect the Value Equity Strategy. The Portfolio Manager’s investment selection is based on identifying the underlying value within companies. The Portfolio Manager looks for investments where the market price of a security is below what the Portfolio Manager believes is its intrinsic value. Although this strategy is primarily focused on small to mid-cap companies, the Portfolio Manager also seeks to be opportunistic within its core competencies and will consider larger companies when appropriate. The Portfolio Manager is not limited to securities trading in particular markets. The Adviser does not claim to be able to forecast general stock market movements or other macroeconomic trends, but instead maintains a long-term investment horizon in its securities selection. 9 Form ADV, Part 2A Firm Brochure January 29, 2026  The Adviser will allocate the portfolio assets among various investments taking into consideration the objectives of the strategy. While the Adviser’s Value Equity Strategy focuses primarily on U.S. and foreign equity securities, such Managed Accounts may also own one or more of the following: convertible stocks, bonds, warrants, corporate, municipal, or government debt, commercial paper, CDs, mutual funds, exchange traded funds, other investment products, and cash and cash equivalents. Select Value Strategy Mr. Robert Robotti, Mr. David Kessler, and Mr. Theo van der Meer are the Portfolio Managers for the Adviser’s Select Value Strategy. The strategy focuses primarily on small- to mid- capitalization companies that are overlooked, out-of-favor or misunderstood by the market and which the Portfolio Managers believe are undervalued. While small to mid-cap at time of purchase these companies may, through merger and/or growth, become larger cap. The Adviser believes that holding larger cap companies is a natural evolution of its buy-and-hold approach with respect the Select Value Strategy. The strategy is based on identifying the underlying value within companies and selecting investments where the market price of a security is below what the Portfolio Managers believe is its intrinsic value. The strategy has limits on sector weighting, market capitalization, and position weighting. Single Issue Strategies Mr. Robert Robotti is the Portfolio Manager for the Adviser’s Single Issue Strategies. The primary investment objective of each strategy is to seek risk-adjusted capital appreciation. Each strategy will attempt to achieve its objective by investing in shares, warrants, derivative and/or debt of one single company. In the event of M&A activity involving the single company in which the strategy invests, the strategy may invest in spinoffs, reinvest dividends, invest in newly formed entities and/or return capital to clients. Concentrated Value Strategy Mr. Robert Robotti is the Portfolio Manager for the Adviser’s Concentrated Value Strategy. The investment strategy is for investors interested in a concentrated portfolio of equity securities. While small to mid-cap at time of purchase these companies may, through merger and/or growth, become larger cap. The primary emphasis is on equities that are selling for significantly less than their intrinsic value or those that may grow their intrinsic value at above average rates. The strategy is highly concentrated, typically owning between 5 and 10 securities at any given time, but may temporarily hold more securities in special situations. The strategy is focused on long-term capital appreciation. The Concentrated Value Strategy is only offered as a Wrap Fee Account and not as a Managed Account. Central Asia Opportunity Strategy Mr. Isaac Schwartz is the Portfolio Manager for the Adviser’s Central Asia Opportunity Strategy. The primary investment objective of the strategy is to seek risk-adjusted capital appreciation. 10 Form ADV, Part 2A Firm Brochure January 29, 2026  The strategy will attempt to achieve its objective by purchasing, trading and investing in shares, warrants, derivatives and/or debt of one particular company based in Central Asia. In the event of M&A activity involving the single company in which the strategy invests, the strategy may invest in spinoffs, reinvest dividends, invest in newly formed entities and/or return capital to clients. Robotti Funds The Adviser advises each Robotti Fund pursuant to customized strategies which seek long exposure to equity markets, including non-U.S. markets, primarily focusing on companies which the Adviser believes to be fundamentally undervalued, exhibit growth potential, and have strong entrepreneurial leadership. The specific strategy of each Robotti Fund is described in each fund’s offering documents provided to investors. Risks of Loss All securities investments involve the risk of loss of capital. The nature of the securities purchased and sold by the Adviser for clients and the investment techniques and strategies employed by the Adviser in an effort to increase profits can increase the risk of loss. Finding and profiting from investment opportunities involve uncertainty, and there can be no assurance that the Adviser will be able to locate investment opportunities or to profit from them. Many unforeseeable events, including actions by governmental authorities, such as the U.S. Federal Reserve Board, failures of banks and financial institutions, and global pandemics can cause sharp market fluctuations that can impact clients’ investments. While the Adviser will act in good faith to manage the client’s account, there can be no assurance that the client’s account will grow or that the client will not incur losses. Stocks. In the U.S., stocks historically have outperformed other types of investments over the long term. Individual stock prices, however, tend to go up and down more dramatically. These price movements may result from factors affecting individual companies or industries, or the securities market as a whole. A slower-growth or recessionary economic environment could have an adverse effect on the price of the various stocks held by an account. Stocks may not increase in price as anticipated by the Adviser. Smaller-Capitalization Companies. The Adviser generally invests in small and mid-cap companies. The securities of small and mid-cap companies may be less liquid, may not trade as often or with as much trading volume, and their prices may be more volatile than those of larger capitalization companies. Accordingly, the Adviser may not be able to sell such securities or liquidate a portfolio that it manages comprised of small and mid-cap companies in an expeditious manner or during a declining market environment. When making large sales, the Adviser may have to sell portfolio holdings at discounts from quoted prices or make a series of small sales over an extended period of time due to the lower trading volume of securities of small and mid-cap companies. The Adviser believes that its approach of holding securities long term helps to offset these risks. 11 Form ADV, Part 2A Firm Brochure January 29, 2026  In addition, investing in smaller companies is riskier than investing in larger companies because they may lack depth of management, financial resources, and the ability to generate funds necessary for growth or development, they may be developing or marketing new products or services for which markets are not yet established and may never become established and they may lack the competitive strength of larger companies. Cyclical Industries. The Adviser frequently invests in cyclical businesses when their industries are going through difficult times because the Adviser believes that investors focus on the current difficult environment and therefore the value of a company's securities may be significantly disconnected from its appropriate mid-cycle valuation. The economic fundamental results of these companies are most likely at some level of stress and dislocation and may deteriorate following investment. Accordingly, the securities of cyclical companies, especially during the difficult times in the business cycle, may frequently be less liquid and extremely volatile. As a consequence, at such times, the Adviser may not be able to sell such securities or liquidate certain components of the portfolio in an expeditious manner or at a favorable price. Frequently, investor sentiment continues to become more pessimistic about the timing of recovery so securities may decline further. The Adviser believes that holding securities long-term frequently makes the most sense on a risk return analysis basis but continuing to hold securities while they are declining entails a risk of capital loss. Sector Underweighting and Overweighting. The Adviser does not attempt to weight its portfolios consistently with the breakdown of sectors in its comparative market index. Therefore, certain industry sectors may be significantly overweighted or underweighted with respect to the weightings in such index, except the Select Value Strategy which has sector weighting limitations. Accordingly, results for client portfolios frequently vary when compared to such index. Furthermore, when the overweighted sectors perform poorly and underweighted sectors perform strongly a client’s account may significantly underperform its comparative market index. Concentration of Positions. The Adviser will regularly invest its portfolios with larger allocations to companies it believes are significantly undervalued. As a result, frequently the 10 largest positions in its portfolios may represent a disproportionate percentage of the total portfolio, except the Select Value Strategy which has limits on the position size for any individual security. When these concentrated positions in the portfolios underperform compared to the comparative market index, the performance of the account will underperform. Material Non-Public Information. Mr. Robotti or employees of the Adviser – including those described in Item 10 below -- will at times acquire material non-public information or be restricted from initiating transactions in certain securities due to membership on the Board of Directors of a company or otherwise. The Adviser is prohibited from acting on such information or during such restricted periods; therefore, at such times the Adviser will not be able to buy an investment that it otherwise might have bought or will not be able to sell an investment that it otherwise might have sold for client accounts. Such a limitation will prevent the Adviser from trading securities of that issuer for a client when the client could otherwise have made a profit or avoided a loss. 12 Form ADV, Part 2A Firm Brochure January 29, 2026  One Company Strategies. Each Single Issue Strategy and the Central Asia Opportunity Strategy invest in the securities of a single issuer (each, a "Subject Company"). Accordingly, the performance of a client’s account depends entirely upon the securities of a single issuer. These strategies do not diversify among a range of issuers, industries, geographic areas, capitalizations or types of securities. As a result, a client’s account may be subject to more rapid changes in value than would be the case if the account were required to maintain a diversification among issuers, industries, geographic areas, capitalizations or types of securities. Moreover, if securities of the Subject Company in which the client’s account is invested fail to appreciate in price, the account will not appreciate in value. If securities of the Subject Company in which the client’s account is invested decline in price, the account will suffer losses. The principal of the Adviser is a member of the Board of Directors of one Subject Company. In the future, the principal or an employee or affiliate of the Adviser may join the Board of Directors (each, a "Robotti Representative") of another Subject Company. Regularly each quarter, and at other times, each Robotti Representative will obtain material non-public information regarding the Subject Company or otherwise be restricted from initiating transactions in securities of the Subject Company due to membership on the Board of Directors of or because he or she has otherwise received such information. Any such restricted period could be for an extended period of time (i.e., 45 or more consecutive days or possibly longer). The Adviser is prohibited from acting on such information or trading securities of the Subject Company during such restricted periods; therefore at such times the Adviser will not be able to buy securities of the Subject Company that it otherwise might have bought or will not be able to sell securities of the Subject Company that it otherwise might have sold for the account. Such a limitation will prevent the Adviser from trading Subject Company securities for the account when the Client may otherwise have avoided a loss or made a profit. Moreover, since there are no securities of any issuer other than the Subject Company in the Single Issue Strategy, the effect will be more pronounced as there will be no other securities to offset any losses or missed gains. Foreign Securities; Foreign Currencies. Investing in foreign securities may represent a greater degree of risk than investing in domestic securities due to exchange rate fluctuations, possible exchange controls, less publicly-available information, different accounting and auditing standards, more volatile markets, less securities regulation, less favorable tax provisions (including possible withholding taxes), political and social upheaval, war, or expropriation. Foreign securities also may be less liquid and more volatile than U.S. securities and may involve higher transaction and custodial costs. information security, and related risks. Cybersecurity Risks. With the increased use of technology to conduct business, the Firm and its affiliates are susceptible to operational, In general, cyber incidents can result from deliberate attacks or unintentional events that can arise from external or internal sources. Cyberattacks 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; corrupting data, equipment, or systems; or causing operational disruption. Cyberattacks can also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on 13 Form ADV, Part 2A Firm Brochure January 29, 2026  websites (i.e., efforts to make network services unavailable to intended users). Cyber incidents affecting the Firm, its affiliates, or any other service providers (including but not limited to custodians and financial intermediaries) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with the ability to calculate asset prices, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which an account invests, counterparties with which an account engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers) and other parties. Client Restrictions The Adviser requires that it be provided with written discretionary authority from the client so that the Adviser may determine which securities and the amounts of securities that are bought or sold. Any investment policies, guidelines or reasonable restrictions on this discretionary authority are included in the written agreement between each client and the Adviser. Clients may change/amend these policies, guidelines and reasonable restrictions at any time by written notice to the Adviser. To the extent that there are restrictions on securities that may be purchased, the client’s account may not perform as anticipated. Deposit of Securities If the client deposits securities into a Separately Managed Account, the Adviser may sell such securities and is not responsible for any losses or diminution in value due to their liquidation. Additional Risks for the Robotti Funds Each Robotti Fund is subject to additional risks that are outlined in the fund’s offering documents provided to investors. Item 9. Disciplinary Information The Adviser and its employees do not have any material legal or disciplinary events. Item 10. Other Financial Industry Activities and Affiliations Affiliated Broker-Dealer Mr. Robert Robotti, the principal of the Adviser, and most employees of the Adviser, are separately licensed as registered representatives of Robotti BD. The Adviser and Robotti BD are sister companies, each owned by Robotti & Company, Incorporated. Robotti BD provides a full range of brokerage services which includes, but is not limited to, executing orders on both a 14 Form ADV, Part 2A Firm Brochure January 29, 2026  principal and agency basis for its brokerage customers, including the Adviser’s clients. Robotti BD acts as an introducing broker to some of the Robotti Funds and some of the Robotti Funds execute substantially all trades in securities through Robotti BD. Pershing LLC acts as Robotti BD’s clearing broker-dealer, under a Clearing Broker Agreement, and acts as custodian for one of the Robotti Funds. Robotti BD may issue research reports on public companies, including companies that may be held in clients’ accounts with the Adviser. Because of the shared management structure of the Adviser and Robotti BD, to the degree any accounts hold shares of companies covered by research analysts of Robotti BD, such shares are from time to time restricted from trading. In addition, certain employees of Robotti BD and the Adviser may discuss publicly certain investments held by the Adviser’s client accounts. The Adviser may impose a trading restriction prior to the date of such public discussion. The Adviser believes that in general any such restricted periods should be brief but can prevent buying and selling securities of the affected issuer for client accounts. As well as receiving investment ideas from third party sources, the Adviser will receive some investment ideas from Robotti BD. Investment ideas shared by Robotti BD with the Adviser may also be used by Robotti BD’s brokerage clients, which consist of both discretionary and non- discretionary accounts (primarily the latter). Conflicts of Interest that Arise in Connection with Allocation of Investment Recommendations Advisory clients, Private Funds (defined below), and Robotti BD brokerage accounts (discretionary and non-discretionary) may purchase, hold or sell the same or different securities of the same issuer. There can be a conflict of interest when Robotti BD purchases or sells a security for an advisory client, a Private Fund or a client of Robotti BD in that purchases or sales of the same security or a related security (e.g., options on the same security or other securities of the same or a related issuer) may have previously been made or are currently being made for another client of the Adviser, another Private Fund or another Robotti BD client. Other than for Wrap Fee Accounts, Robotti BD receives a per trade commission on most securities transactions it executes; accordingly, Robotti BD has an incentive to disseminate these recommendations to its clients in order to earn as many commission dollars as possible. Clients should be aware that some investment opportunities identified by employees of the Adviser for any of the Related Person Funds, as defined below, may not be shared with the Adviser’s Portfolio Managers or may be shared following investment by the relevant fund. Similarly, some investment opportunities identified by the Portfolio Managers of the Managed and Wrap Fee Accounts, or the portfolio managers of other Robotti Funds are not used in the Managed and Wrap Fee Accounts but are used instead in the Robotti Funds and some of such investment opportunities are used in the Managed and Wrap Fee Accounts and not in the Robotti Funds. 15 Form ADV, Part 2A Firm Brochure January 29, 2026  The Adviser does not favor any client or group of clients over another. The Adviser and Robotti BD manage these conflicts of interest through implementing and monitoring compliance procedures relating to equitable allocation of investment opportunities. Conflicts of Interest Procedures When a particular trade or investment recommendation creates the potential for a conflict of interest: (1) the appropriate representative of the Adviser or Robotti BD will enter the order for the Adviser’s client or Robotti BD’s discretionary client, or recommend the transaction to the Robotti BD non-discretionary client, only if he or she has a reasonable belief that the proposed transaction is in the client's best interest; then (2) if orders of the same securities are being executed at the same time for clients of the Adviser (including certain Private Funds) and/or of Robotti BD and all such clients’ accounts are custodied at the same custodian, each account for which an order is being executed will receive the weighted average price for such orders. In all other circumstances, including clients with accounts custodied at different custodians and clients custodied at the same custodian whose orders are executed at different times during the same day, market fluctuations, order size and execution time may result in different prices for transactions executed on the same day. Outside Business Activities of the Principal Owner Mr. Robotti is the president of Robotti BD, which is a broker-dealer affiliated with the Adviser and is the introducing broker for the Wrap Fee Accounts and some of the Robotti Funds. In addition to Mr. Robotti’s management responsibilities for the Adviser and Robotti BD and his portfolio management duties for the Adviser, Mr. Robotti also manages the assets of certain discretionary brokerage clients of Robotti BD. Mr. Robotti’s brokerage activities currently include researching securities to identify attractive investment opportunities for Robotti BD’s brokerage clients. Mr. Robotti also is a principal of the general partner (or the managing member), of and the portfolio manager of some, of the Robotti Funds. In addition, Mr. Robotti serves as a director of two U.S. public companies and the chairman of one Canadian public company: Pulse Seismic Inc. (Toronto - PSD), December 2007 to present AMREP Corporation (NYSE – AXR), September 2016 to present Tidewater Inc. (NYSE – TDW), May 2021 to present Due to Mr. Robotti’s activity with these public companies, the Adviser may be subject to restrictions on trading in these and other related public companies. Mr. Robotti is compensated and has his expenses reimbursed by these public companies for this Board activity. 16 Form ADV, Part 2A Firm Brochure January 29, 2026  Mr. Robotti or affiliates (and possibly other related persons) are investors in private investment funds that invest in securities and are Robotti BD clients. In addition, Mr. Robotti or affiliates may invest in the securities of issuers whose management personnel are clients of the Adviser or Robotti BD. The Adviser maintains procedures to prevent the parties subject to such relationships from obtaining a preference in investment opportunities over other clients of the Adviser. Related Person Funds Five employees of the Adviser and/or Robotti BD are each also involved in the management of a different private fund (each, a “Related Person Fund,” and together with the Robotti Funds, the “Private Funds”). 1. Alan Weber, a research analyst with the Adviser and a registered representative of Robotti BD, is the general partner and portfolio manager of a Related Person Fund. 2. Daniel Grzywacz, a senior investment associate with the Adviser and a registered representative of Robotti BD, is the managing member and portfolio manager of a Related Person Fund. 3. Brian Weber, a senior investment associate and registered representative with Robotti BD, is the general partner and portfolio manager of a Related Person Fund. 4. Robert Scheuing, a senior investment associate and registered representative with Robotti BD, is the general partner and portfolio manager of a Related Person Fund. 5. David Kaiser, a senior investment associate with the Adviser and a registered representative with Robotti BD, is the general partner and portfolio manager of a Related Person Fund. The Adviser's clients may be solicited to invest in any Private Fund; however, the Adviser will not use its discretionary authority to invest a client’s account in any Private Fund. Brokerage Practices. See Item 12 – “Brokerage Practices – Principal Trades and Agency Cross Transactions” below for a discussion of transactions executed between and among Robotti BD and the Adviser. Item 11. Code of Ethics The Adviser has adopted a Code of Ethics setting forth high ethical standards of business conduct that the Adviser requires of its employees, addressing personal securities transactions of employees known as “Access Persons” and prohibiting the misuse of non-public material information by employees of the Adviser. Employee Trading in Securities 17 Form ADV, Part 2A Firm Brochure January 29, 2026  The Adviser has adopted the following principles governing personal investment activities by the Adviser's supervised persons: • The interests of client accounts will at all times be placed first; • All personal securities transactions will be conducted in such manner as to avoid any actual or potential conflict of interest or any abuse of an individual’s position of trust and responsibility; • Supervised persons are not permitted to take inappropriate advantage of their positions; and • If an employee trades the same security in a single day when a client account is trading such security: (i) if the employee’s price is better than the price received by the client account, then both trading prices are averaged at the end of the trading day and both parties receive the weighted average price; (ii) if the employee receives a price that is worse than the price received by the client account, then the employee’s price will not change; and (iii) the employee will not receive a price that is better than the worst price received by a client account during the trading day. The Adviser and its personnel may solicit clients to invest in the Private Funds which are managed by Mr. Robotti or certain employees of the Adviser. See Item 8 “Methods of Analysis, Investment Strategies and Risk of Loss -- Investment Strategies -- Robotti Funds” and Item 10 “Other Financial Industry Activities and Affiliations -- Related Person Funds.” The Adviser’s policy is to allocate purchases and sales fairly among advisory clients, and in circumstances when it is in the client’s interest to make a particular purchase or sale, the Adviser gives such clients priority over those purchases and sales made for the accounts of the Adviser’s related parties. The Adviser, its employees and the Private Funds frequently hold securities of companies that the Adviser purchases or sells for clients. These purchases or sales are only made if they are in the best interest of a client. These purchases or sales for clients are not intended to provide a financial advantage to the Adviser, its employees or Private Funds who already hold such securities. The transactions are only effected for clients when it is in their best interests. A conflict of interest may arise when the Adviser and its employees recommend a Private Fund which has the potential to produce higher compensation to the Adviser than other investment products which the Adviser offers, such as Managed Accounts and Wrap Fee Accounts. When making this determination, the Adviser and its employees must consider all factors including compensation to the Adviser, which may cause higher costs to the client, as well as the lack of liquidity of Private Funds. In accordance with the Firm’s Code of Ethics, the Adviser and its employees may only recommend Private Funds to clients when it is in the best interest of a client to purchase an interest in such Private Fund. 18 Form ADV, Part 2A Firm Brochure January 29, 2026  The Code of Ethics includes policies and procedures requiring Access Persons to submit information on securities transactions and compliance staff to review such reports periodically. The Adviser’s Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. The Code of Ethics also includes oversight, enforcement and recordkeeping provisions. Material Non-Public Information In accordance with Section 204A-1 of the Investment Advisers Act of 1940, the Adviser also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by the Adviser or any person associated with the Adviser. A copy of the Adviser’s Code of Ethics is available to clients upon written request to the Adviser’s Chief Compliance Officer. Upon its receipt, all employees must report the acquisition of material non-public information regarding an issuer to the Chief Compliance Officer. Thereupon, compliance staff takes immediate action to include affected companies on the Adviser’s and Robotti BD’s Restricted List, and to alert all employees of the addition to the List. All supervised persons are prohibited from transacting in any securities included in the Restricted List. Gift and Entertainment Policy An employee is prohibited from giving a gift or providing entertainment where the employee intends to cause the recipient to act in a manner that is inconsistent with the best interests of a client or the Adviser. All employees must complete the Gift and Gratuity Form and obtain approval from the Chief Compliance Officer prior to giving a gift or providing entertainment, or upon receiving a gift or being provided entertainment. Entertainment is appropriate only when it is used to foster business relationships. Item 12. Brokerage Practices Use of Affiliated Broker Dealer Please see Item 10. “Other Financial Industry Activities and Affiliations – Affiliated Broker- Dealer.” Principal Trades and Agency Cross Transactions A principal transaction is a transaction where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also occur if a security is crossed between a Private Fund and another advisory client account. 19 Form ADV, Part 2A Firm Brochure January 29, 2026  An agency cross transaction is a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. The Adviser will never engage in principal or agency cross transactions for its clients that are pension or profit sharing plans subject to Employee Retirement Income Security Act of 1974, as amended ("ERISA"). The Adviser will not place principal trades for any non-ERISA client accounts unless the client has been advised in writing of, and the advisory client’s written consent is obtained thereto, on a trade-by-trade basis, in advance of the settlement date: (i) the capacity in which the Adviser or its affiliate is acting, (ii) either the cost to the Adviser of the security if sold to a client or the price at which the security could be resold if purchased from a client, (iii) the best price at which the transaction could be effected elsewhere if more advantageous and (iv) the proposed commission. In the case of agency cross transactions, the Adviser will only place such orders when: 1. The Adviser considers the transaction to be in the interest of advisory clients and the transaction to be consistent with its fiduciary obligations to clients, including best execution, and 2. The advisory client has authorized such transactions in its investment advisory agreement with the Adviser (and such authority has not been previously revoked by the client). When executing an agency cross transaction, Robotti BD’s clearing broker will cause a written confirmation to be sent to the client at or prior to settlement of the transaction. Additionally, the Adviser will send a notification that includes information about the nature of the transaction, the date of the transaction, an offer to furnish upon request the time the transaction occurred and the source and amount of any other remuneration received or to be received by the Adviser and any other person relying upon Investment Adviser’s Act Rule 206(3)-2 (the SEC’s rule permitting agency cross transactions). If there are any agency cross trades in a client’s account, the Adviser will provide a client with an annual summary of all agency cross-trades in the client’s account during the prior year, including the total number of transactions and total commissions received by Robotti BD, and a statement that the client may terminate agency cross trade authority in writing at any time. In the event that the Adviser executes an agency cross transaction, the Adviser will negotiate a purchase or sale price on behalf of a client with the counterparty. Generally, the execution price of a purchase per unit of a security will be no higher than the lowest current open market ask price and the total price of a sale per unit of a security will be no lower than the then highest current open market bid price. Soft Dollars The Adviser does not have any soft dollar arrangements with respect to the Separately Managed Accounts. The Robotti Funds may be deemed to be paying for research and brokerage services 20 Form ADV, Part 2A Firm Brochure January 29, 2026  with "soft" or commission dollars. Although the Adviser believes that the applicable fund will benefit from many of the services obtained with "soft" dollars generated by the fund trades, the fund may not benefit from all of these "soft" dollar services. The managing member or general partner of the Robotti Funds, the Adviser and their affiliates, principals, employees and such other accounts and entities may derive direct or indirect benefits from these services. When the Adviser uses client brokerage commissions to obtain research or other products or services, it receives a benefit because it does not have to produce or pay for the research products or services. The Adviser may have an incentive to select or recommend a broker-dealer based upon its interest in receiving the research on other products or service, rather than its clients’ interest in receiving most favorable execution. The Adviser may only use a broker if the Adviser determines that the broker will achieve the best overall qualitative execution for the client’s account. Client Referrals Neither the Adviser nor Robotti BD considers referrals from third parties in selecting or recommending broker-dealers for the Adviser. Directed Brokerage Client accounts that are brought to the Adviser through the Consultant (discussed above in Item 4), and certain other accounts, have directed the Adviser to participate in the Schwab Advisor Services program offered by Charles Schwab & Company, Inc. (“Schwab”). The Consultant recommends that its clients to whom it refers the Adviser as adviser, direct the Adviser to place trades with Schwab, as broker dealer and custodian of their accounts. By instructing the Adviser to execute all transactions on behalf of the Managed Account through Schwab, the commissions borne by the Managed Account may be greater than the commissions borne by the Adviser’s other clients that do not direct the Adviser to use a particular broker-dealer. Also, by instructing the Adviser to execute all transactions on behalf of the Managed Account through Schwab, the client may obtain commission rates and execution that are less favorable than those that would be obtained if the Adviser were able to place transactions with other broker-dealers. The client may also forego benefits that the Adviser may be able to obtain for its other clients through, for example, negotiating volume discounts or block trades. Accordingly, the Adviser will not seek best execution of the client’s transactions through other broker-dealers. Although the Adviser’s execution procedures are designed to endeavor to obtain the best execution possible for its Managed Accounts, since Schwab is the sole broker-dealer for the client’s Managed Account, there can be no assurance that best execution will be obtained. Not all investment advisers recommend that clients direct brokerage to a single broker. The client should consider whether or not the appointment of Schwab as the sole broker may result in certain additional costs or other disadvantages to the client as a result of possibly less favorable executions and thereby may cost the client more money. Select Value Strategy. Client accounts invested in this strategy are custodied at Interactive Brokers, LLC (“IBKR”). The Adviser recommends that its clients utilize IBKR, as broker-dealer and custodian of their accounts, and all trades must be made through IBKR. By instructing the Adviser 21 Form ADV, Part 2A Firm Brochure January 29, 2026  to execute all transactions on behalf of the Managed Account through IBKR, the commissions borne by the Managed Account may be greater than the commissions borne by the Adviser’s other clients that do not direct the Adviser to use a particular broker-dealer. Also, by instructing the Adviser to execute all transactions on behalf of the Managed Account through IBKR, the client may obtain commission rates and execution that are less favorable than those that would be obtained if the Adviser were able to place transactions with other broker-dealers. The client may also forego benefits that the Adviser may be able to obtain for its other clients through, for example, negotiating volume discounts or block trades. Accordingly, the Adviser will not seek best execution of the client’s transactions through other broker-dealers. Although the Adviser’s execution procedures are designed to endeavor to obtain the best execution possible for its Managed Accounts, since IBKR is the sole broker-dealer for the client’s Managed Account, there can be no assurance that best execution will be obtained. Not all investment advisers recommend that clients direct brokerage to a single broker. The client should consider whether or not the appointment of IBKR as the sole broker may result in certain additional costs or other disadvantages to the client as a result of possibly less favorable executions and thereby may cost the client more money. Single Issue Strategies and Central Asia Opportunity Strategy. Transactions for each of the Single Issue Strategies and the Central Asia Opportunity Strategy are executed through Robotti BD (here, the “Directed Broker”), a broker-dealer affiliated with the Adviser through ownership and control, as the sole introducing broker. Client understands that by instructing the Adviser to execute all transactions on behalf of the Account through the Directed Broker, Adviser will not seek best execution of client’s transactions through other broker-dealers. Although the Adviser’s execution procedures are designed to endeavor to obtain the best execution possible for its Accounts, since the Directed Broker is the sole broker-dealer for the client’s Account, there can be no assurance that commission rates and execution will be as favorable as those that would be obtained if the Adviser were able to place transactions with other broker-dealers. Not all investment advisers require clients to direct brokerage to a single broker. Accordingly, the Client should consider whether or not the appointment of the Directed Broker as the sole broker may or may not result in certain costs or disadvantages to the client as a result of possibly less favorable executions and thereby may cost the client more money. Trade Aggregation Aggregating trades of multiple clients allows the Adviser to execute equity trades for many accounts in a timelier, more equitable manner. The Adviser will at times aggregate trades of multiple accounts custodied at the same custodian and allocate the shares purchased in accordance with an allocation methodology. Generally, because they are custodied at different custodians, Wrap Fee Account trades will not be aggregated with Managed Account trades; however, Wrap Fee Account trades will at times be aggregated with transactions of Private Funds and clients of Robotti BD. Client trades that are aggregated receive the weighted average price of such trades. In all other circumstances, including clients with Wrap Fee or Managed Accounts custodied at different custodians and clients custodied at the same custodian whose orders are 22 Form ADV, Part 2A Firm Brochure January 29, 2026  executed at different times during the same day, market fluctuations, order size and execution time may result in different prices for transactions executed on the same day. Item 13. Review of Accounts Managed Accounts The Adviser conducts reviews of Managed Accounts internally on a regular basis at least quarterly and, except as specified below, will rebalance such accounts as necessary. Managed Accounts will be provided with written information from the Adviser at least annually. For taxable accounts the Adviser may sell positions on the client’s behalf to incur capital losses and thereby offset capital gains at any time on an as needed basis. Reviews are conducted by Portfolio Managers of the Adviser. Single Issue Strategy and Central Asia Opportunity Strategy. Because each Single Issue Strategy and the Central Asia Opportunity Strategy is focused on the securities of a single issuer, accounts in these strategies are never rebalanced. Additional shares may be purchased as dividends are received, or capital contributions are made to the accounts. Wrap Fee Accounts The Adviser conducts reviews of Wrap Fee Accounts internally on a regular basis and will rebalance as necessary. Wrap Fee Accounts will be provided with written information from the Adviser at least quarterly. For taxable accounts the Adviser may sell positions on the client’s behalf to incur capital losses and thereby offset capital gains at any time as needed. Reviews are conducted by Portfolio Manager of the Adviser. General – Separately Managed Accounts. If the Adviser is notified of changes in a client's situation, such as investment goals financial position or individual investment developments, or if there are unusual economic or industry developments, such change may trigger an account review. Clients receive statements from their custodians at least quarterly. These statements will show the current market values and transactions during the past quarter (or month for any monthly statements) as well as interest and dividends for the reporting period. For purposes of review and client discussions, the Adviser prepares account summaries from our internal records that show holdings. The Adviser recommends that clients review these statements regularly to ensure accuracy and check them against their custodial statements to ensure there are no discrepancies. Robotti Funds The managing member or general partner, as applicable, of each Robotti Fund generally provides investors in that fund with performance data and other information periodically, and at least annually. 23 Form ADV, Part 2A Firm Brochure January 29, 2026  Item 14. Client Referrals and Other Compensation As discussed above in Item 4, above, some clients and investors are referred to the Adviser by the Consultant; however, the Consultant’s fees (whether management or performance) are paid by the client and not by the Adviser. Some clients are referred to the Robotti Funds by Affiliated Solicitors who are registered representatives of Robotti BD but are not supervised persons of the Adviser. Robotti BD is compensated for such referrals by the Adviser and/or the general partner or managing member of the Robotti Fund receiving the referral pursuant to the terms of a placement agent agreement and at no additional cost to the client. In addition, Robotti BD, which acts as introducing broker for some Wrap Fee Accounts and for some of the Robotti Funds, routes customer orders to various exchanges, alternative trading systems (ATSs), including electronic communications networks (ECNs), and other market centers. Certain market centers offer cash credits for orders that provide liquidity to their books and charge fees for orders that extract liquidity from their books. Periodically, the amount of credits that Robotti BD receives from one or more such market centers may exceed the amount that Robotti BD is charged. Under these limited circumstances, such payments might be considered payment for order flow. Any such cash credits or payment for order flow is not a determining factor for decisions on how to route an order nor does it factor into the Adviser’s best execution procedures. Although particular transactions may receive a benefit due to reduced commission charges, overall the amounts received are immaterial to Robotti BD. Some clients are referred to the Robotti Funds by an unaffiliated broker-dealer. The unaffiliated broker-dealer is compensated for such referrals by the Adviser and/or the general partner or managing member of the Robotti Fund receiving the referral pursuant to the terms of a placement agent agreement and at no additional cost to the client. Item 15. Custody The Managed Accounts that are introduced by the Consultant, and certain other accounts, are custodied at Schwab. Accounts invested in the Select Value Strategy are custodied at Interactive Brokers, LLC. The Adviser’s Wrap Fee Accounts and other Managed Accounts are primarily custodied at Pershing LLC. Although the Adviser does not have possession of the funds and securities for the Value Equity Strategy, Select Value Strategy, Single Issue Strategy and Central Asia Opportunity Strategy Accounts, for purposes of the SEC’s Custody Rule, the Adviser is deemed to have custody of such funds and securities due to its authority to deduct fees from such accounts. In addition, although the Adviser does not have possession of the funds and securities in its Wrap Fee Accounts employing its Value Equity Strategy and Managed Accounts in its Single Issue Strategy and Central Asia Opportunity Strategy, because Robotti BD, the Adviser's affiliate, is authorized or permitted to withdraw client funds or securities maintained with the client's custodian upon its instruction to the custodian, for purposes of the SEC’s Custody Rule, the Adviser is deemed to have custody of such funds and securities. Your custodian will send you account statements quarterly, or more frequently. You should carefully review your account statements. In addition, the Adviser urges you to compare the quarterly statements you receive from the Adviser with those you receive from your custodian. Please see Item 5 “Fees and Compensation – Managed Accounts – Account Valuation” for important information 24 Form ADV, Part 2A Firm Brochure January 29, 2026  regarding differences between the values used on the Adviser’s statement to you and your statement from your custodian. Robotti Funds The Adviser is deemed to have custody of the funds and securities of the Robotti Funds because an affiliate of the Adviser is the managing member or general partner of those funds and has access to such funds and securities. Each of the Robotti Funds receives an independently audited financial statement completed after the end of the calendar year. Investors will also receive certain tax information for preparation of their respective tax returns. Other periodic reports may be provided by the fund’s managing member or general partner. Item 16. Investment Discretion The Adviser offers investment management services on a discretionary and non-discretionary basis. In the client's discretionary investment advisory agreement, the client grants the Adviser investment discretion consistent with the stated investment objectives for the client account. Investment discretion includes the authority to select the securities and the amount and timing of purchases and sales for the client's account without obtaining consent or approval prior to each transaction. The client may impose certain investment policies, guidelines or reasonable restrictions on how the account is managed including restrictions on investing in certain securities or types of securities. Clients may change or amend these policies, guidelines and restrictions in writing to the Adviser. Item 17. Voting Client Securities When a client opens an account, the client agrees to delegate its proxy voting authority to the Adviser. The Adviser votes these proxies in the best interests of its clients and in accordance with the Adviser’s established policies and procedures. Clients may not direct a vote in a particular solicitation. With respect to accounts subject to ERISA, the Adviser will vote proxies unless the plan documents specifically reserve the plan sponsor’s right to vote proxies. If any client requests in writing a copy of the Adviser’s complete proxy voting policies and procedures or how the Adviser voted proxies for its account(s), the Adviser will promptly provide such information to the client. Generally, other than in the case of Board service for a portfolio company, in the event of any conflict identified by the Adviser in voting a proxy, the Adviser will inform the client of the conflict and, if appropriate, request that the client direct the Adviser as to how to vote. There may appear to be a conflict of interest when the Private Funds or client’s securities are voted in favor of election or re-election of the principal or an employee of the Adviser as a member of a portfolio company’s Board of Directors. However, the Adviser only permits Board service when it is in the best interest of the Adviser’s clients and Private Fund investors to have a representative on the Board of Directors of a portfolio company. 25 Form ADV, Part 2A Firm Brochure January 29, 2026  Item 18. Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about the Adviser’s financial condition. The Adviser has no financial commitment that is reasonably likely to impair its ability to meet contractual commitments to clients, and has not been the subject of a bankruptcy proceeding. 26 Form ADV, Part 2A Firm Brochure January 29, 2026