General Disclaimer

The home offices of Robotti Securities, LLC and Robotti & Company Advisors, LLC are located in New York, NY.

Robotti Securities, LLC (“Robotti BD”) is a registered broker-dealer, member FINRA/SIPC. Products and services mentioned in this website may not be available in all states. To request information, contact your registered representative at Robotti BD. Robotti BD is also a member of the Securities Investor Protection Corporation (SIPC). You may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at www.sipc.org or (202) 371-8300.

Investment advisory services are provided by Robotti & Company Advisors, LLC (“Robotti IA”), a SEC registered investment adviser. Information about those investment advisory services may be reviewed in the Form ADV Part I and Part II A brochures filed by Robotti IA. Contact your investment advisory associate at Robotti IA for the current form or please visit the following website: https://adviserinfo.sec.gov/IAPD/IAPDFirmSummary.aspx?ORG_PK=128093.

The information and opinions on this site provided by third parties have been obtained from sources believed to be reliable, but accuracy and completeness cannot be guaranteed. It is given for informational purposes only and is not a solicitation to buy or sell. This information is not intended to be used as the primary basis for investment decisions, nor should it be considered as advice designed to meet the specific needs of an individual investor. Robotti BD and Robotti IA are not in a position to provide tax advice. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific information, opinion, advice, or other content.

Robotti BD, Robotti IA, and their affiliates or divisions are not banks, and the products offered are not federally guaranteed or FDIC insured, are not deposits or obligations of, and are not guaranteed by a financial institution. All such products may involve risks which can include possible loss of principal and fluctuation in value.

Linked third-party websites are not under the control of Robotti BD or Robotti IA and neither company nor their affiliates are responsible for the contents of any linked website, any link(s) contained in a linked website, or any changes or updates to such websites.

Robotti BD and Robotti IA, including their respective agents and representatives, may only transact business in a particular state after licensure or satisfying qualifications requirements of that state, or only if they are excluded or exempted from the state’s broker-dealer, investment adviser, broker-dealer agent or investment-adviser representative requirements. The information provided on this site or in any communication containing a link to this site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Robotti BD, Robotti IA or any of their affiliates to any registration requirement within such jurisdiction or country.

Individualized responses to consumers in a particular state by broker-dealer, investment adviser, broker-dealer agent or investment-adviser representative that involve either the securities or the rendering of personalized investment advice for compensation, as the case may be, shall not be made without first complying with the state’s specific regulatory requirements, or pursuant to an applicable state exemption or exclusion.

Robotti BCP Disclosure Statement

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Customer Identification Program Notice

Important Information You Need to Know About Opening A New Account

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.

This Notice answers some questions about the Customer Identification Program of Robotti Securities, LLC (“Robotti BD”) and Robotti Company Advisors, LLC (“Robotti IA”).

What types of information will I need to provide?

When you open an account with Robotti BD or commence an investment advisory relationship with Robotti IA, both Robotti BD and Robotti IA will collect information such as the following from you:

• Your name
• Date of birth
• Address
• Identification number:
  • U.S. Citizen: taxpayer identification number (social security number or employer identification number)
  • Non-U.S. Citizen: taxpayer identification number, passport number, and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you.

You may also need to show your driver’s license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement.

U.S. Department of the Treasury, Securities and Exchange Commission, NASD, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance.

What happens if I don’t provide the information requested or my identity can’t be verified?

Robotti BD and Robotti IA may not be able to open an account or carry out transactions for you. If Robotti BD has already opened an account for you or Robotti IA has already entered in an investment advisory relationship with you, we may have to close the account or termination the relationship.

We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.

Privacy Statement

Robotti Securities, LLC (“Robotti BD”), Robotti and Company Advisors, LLC (“Robotti IA”), and our affiliates have the utmost respect for our customers’ privacy, and we are highly committed to protecting your privacy. In furtherance of this commitment, we are providing our individual customers with this privacy statement, and the opportunity to direct us not to provide certain nonpublic personal information to our affiliates and other third parties.

The Types of Information We Collect About You:

Robotti BD and Robotti IA collects nonpublic personal information about you from: information we receive from you on applications or other forms; the transactions you have participated in with us, our affiliates, or others; and, from information we receive from a consumer-reporting agency.

The Types of Information We Disclose About You:

We may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf, or to other financial institutions with whom we have joint marketing agreements. We may also disclose the information as described above, and as permitted by law, to our affiliates. Our affiliates are those parties who, directly or indirectly, hold common ownership with Robotti BD and Robotti IA. We treat nonpublic personal information about former customers in the same manner, and with the same care that we do our current customers. We only disclose nonpublic personal information about those former customers who had an opportunity to opt out.

The Types of Information We Disclose About You:

We may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf, or to other financial institutions with whom we have joint marketing agreements. We may also disclose the information as described above, and as permitted by law, to our affiliates. Our affiliates are those parties who, directly or indirectly, hold common ownership with Robotti BD and Robotti IA. We treat nonpublic personal information about former customers in the same manner, and with the same care that we do our current customers. We only disclose nonpublic personal information about those former customers who had an opportunity to opt out.

Your Right to Opt Out:

Other than those disclosures required by law, you may direct us not to disclose nonpublic personal information about you to: our affiliates; to companies that perform marketing services on our behalf; or to other financial institutions, with whom we have joint marketing agreements. If you wish to do so, you may fill out the opt-out form enclosed, and mail it to the address provided.

Our Information Security Policies:

In order to protect the confidentiality and security of the nonpublic personal information that Robotti BD and/or Robotti IA gathers from you, access to that information is restricted to select members of our staff. These select staff members are privy to said information on a need to know basis, only to the extent necessary to fulfill your requests and provide you with the best service possible. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

E-Mail Communication Policy

 Confidentiality

• E-mail communication and any of its accompanying document(s) are confidential and privileged. They are intended for the sole use of the addressee.
  If you receive an e-mail transmission in error, you are advised that any disclosure, copying, distribution or the taking of any action in reliance upon the communication is strictly prohibited. If you received an e-mail in error, please contact our office at (212) 986-4800.

Account Information

• Trading instructions sent via e-mail will not be honored. If you need to place a trade to buy or sell securities, please contact the main office at (212) 986-4800 and ask to speak with your registered representative.
• Please be advised that communications regarding trades in your account are for information purposes only. You should continue to rely on confirmations and statements received from the custodian(s) of your assets.

FINRA Public Disclosure Program

FINRA BrokerCheck is a free online tool to help investors check the professional background of current and former FINRA-registered securities firms and brokers such as Robotti Securities, LLC. For questions regarding BrokerCheck, or to request an Investor Brochure, FINRA provides a toll-free hotline, (800) 289-9999, available Monday through Friday from 8 a.m. until 8 p.m., Eastern Time. This research tool can be found online at www.finra.org.

For information regarding SEC disclosure information on Robotti & Comany Advisors, LLC, contact www.sec.gov, or utilize the following link: http://www.adviserinfo.sec.gov/IAPD/Content/Search/iapd_OrgSearch.aspx

Termination of Research Report Disclosure

From time to time, Robotti Securities, LLC may terminate research coverage on a listed company. Effective upon our termination of coverage, the last recommendation and estimates should not be relied upon going forward. A final report will be issued, and the final report will remain on the website for 15 days after the next annual quarter end. At that time it will be removed from this website. For historical information regarding listed companies which are no longer covered by Robotti Securities, LLC, please contact your registered representative.

Robotti BD SEC Rule 605 Order Execution Disclosure

SEC Rule 605 requires OTC market makers, exchange market makers, national securities exchanges, and other market participants to make available monthly reports of statistical data regarding order execution for “covered orders” as defined under the Rule.

The reports for Robotti Securities, LLC can be accessed below:

http://public.s3.com/rule605/robt/

Robotti BD Rule 606 Order Routing Disclosure

SEC Rule 606 requires all broker-dealers that route orders in equity and option securities to make available quarterly reports that present an overview of their order routing practices. The report requires us to identify the significant venues to which client orders were routed for execution during the previous quarter and disclose the material aspects of the broker-dealer’s relationship with such venues. In addition, the rule requires broker-dealers to disclose, on customer request, the venues to which the customer’s individual orders were routed.

The reports for Robotti Securities, LLC can be accessed below:

http://external.s3.com/rule606/mixit_rbi/

MARGIN DISCLOSURE STATEMENT

Securities purchased on margin are Robotti BD’s and Pershing’s collateral for the loan to you. If the securities in your account declines in value, so does the value of the collateral supporting your loan, and, as a result, Robotti BD or Pershing can take action, such as require you to provide additional funds to Pershing to avoid the forced sale of those securities or other securities or assets in your account (issue a margin call) and/or sell securities or other assets in any of your accounts held with Pershing in order to maintain the required equity in the account. It is important that you fully understand the risks involved in trading securities on margin. These risks include the following:

• You can lose more funds than you deposit in the margin account.
• Robotti BD or Pershing can force the sale of securities or other assets in your account.  You also will be responsible for any shortfall in the account after such a sale.
• Robotti BD or Pershing can sell your securities or other assets without contacting you if the equity in your account falls below Pershing’s maintenance margin requirements or Robotti BD’s higher “house” requirements.
• You are not entitled to choose which securities or other assets in your account are liquidated to meet a margin call.
• Robotti BD or Pershing can increase the amount of equity you are required to keep in the margin account or reduce the amount of time you will have to satisfy any margin call at any time and is not required to provide you advance written notice.
• You are not entitled to an extension of time on a margin call.
• Customers borrowing securities will incur charges
• Pershing has the right to collect any debit balance or other obligations owed by assigning such rights to Robotti BD, so that Robotti BD may collect any such debit balance or other obligations independently or jointly with Pershing, or enforce any other rights granted to Pershing.

Investors Exchange Rule Book

IEX Rule 8.1110 requires that Robotti Securities, LLC make available a current copy of the IEX Rules for customers upon request.  The current IEX Rule Book can be accessed at the following link:

https://iextrading.com/docs/Investors%20Exchange%20Rule%20Book.pdf

Robotti Broker Dealer Annual Disclosure to Customers 2023