Dudley & Shanley, Inc.

Dudley & Shanley, Inc. is a registered investment adviser with the SEC, established in 1986 as a New York limited partnership. The firm offers discretionary account management services to individuals, trusts, and charitable institutions, focusing on long-term capital appreciation and capital preservation through investments in various securities. The firm also manages three pooled investment vehicles. Clients are required to start with a minimum of $5 million, which may be waived at the firm's discretion. The firm's fee structure is tiered based on assets under management, with fees ranging from 0.50% to 1.00% per annum. Dudley & Shanley does not charge performance-based fees and acts with investment discretion, making decisions without prior client consent. The firm's investment philosophy involves fundamental analysis, supplemented by various techniques, and aims to achieve above-average returns by investing in well-managed companies. Clients receive regular reports on their accounts' performance and holdings. The firm has not been subject to any material disciplinary actions and does not compensate third parties for client referrals. Dudley & Shanley has custody of the assets held by the Funds and exercises voting rights on client securities in their best interests. The firm's financial condition is sound, with no known impairments to meeting contractual commitments.