Lombard

Lombard Investments, Inc. is a California corporation established in 1985, offering discretionary investment management services to private partnerships and investment funds primarily focused on the Asia-Pacific region. The firm is owned by senior professional staff members and affiliated with Lombard Holdings and Lombard Investments (HK) Limited. Lombard provides tailored investment advice to Funds, not individual investors, with terms specified in each Fund's Governing Documents. The firm manages over $304 million in assets across various Funds. Lombard charges management fees negotiated with Investors and may receive additional fees from portfolio companies. The firm does not participate in wrap fee programs and does not accept compensation for selling securities. Clients are accredited investors, and the firm follows a general investment strategy of building diversified portfolios in middle-market companies. Lombard's investment approach includes aligning interests, strategic planning, and promoting corporate governance standards. The firm discloses potential risks associated with investing in the Asia-Pacific region and newly established companies. Lombard has a Code of Ethics and Policies on insider trading and personal trading to manage conflicts of interest. The firm does not engage in principal transactions and has a Voting of Securities Policy to guide proxy voting decisions. Lombard does not require prepayment of fees and has no financial conditions impairing its commitments to Funds.