Compass Group Management LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
8111526
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Keller, Stephen, Andrew
(For individuals, Last, First,
Middle)
CRD
Number:
2725502
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SABO, ELIAS, JOSEPH

(For individuals, Last, First,
Middle)
CRD
Number:
5216342
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FAULKINGHAM, RYAN, JAMES
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
ROBERT J. MATTHEWS, INDIVIDUALLY, AND ON BEHALF OF ALL OTHER SIMILARLY SITUATED, AS PLAINTIFF
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
CIVIL MONEY DAMAGES
3.
Filing Date of Court Action (MM/DD/YYYY):
05/09/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
FILED IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA (CASE NO. 8:25-CV-00981)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE CIVIL ACTION IS A CLASS ACTION FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS. THE ALLEGATIONS ARE FOR VIOLATION BY THE
DEFENDANTS OF: (I) OF SECTION 10(B) OF SECURITIES EXCHANGE ACT OF 1934, AS AMENDED ("EXCHANGE ACT") AND SEC RULE 10B-5 THEREUNDER,
AND (II) SECTION 20(A) OF THE EXCHANGE ACT.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
05/22/2025
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.

11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
THE SUPERVISORY AFFILIATES OF THE ADVISER NAMED IN THIS DRP WERE INCLUDED AS DEFENDANTS IN A CIVIL PROCEEDING AGAINST COMPASS
DIVERSIFIED HOLDINGS (THE "TRUST") AND COMPASS GROUP DIVERSIFIED HOLDINGS, LLC (THE "COMPANY") (THE TRUST AND COMPANY TOGETHER
ARE REFERRED TO AS "CODI") AND MORDECHAI HAIM FERDER. THE COMPANY IS A CLIENT OF THE ADVISER PURSUANT TO A MANAGEMENT SERVICES
AGREEMENT ("MSA") PURSUANT TO WHICH THE ADVISER AND ITS EMPLOYEES PROVIDE MANAGEMENT SERVICES AND OTHER ADMINISTRATIVE
SUPPORT SERVICES, INCLUDING THE SECONDMENT OF ELIAS J. SABO AND STEPHEN KELLER AND HIS PREDECESSOR RYAN J. FAULKINGHAM, TO THE
COMPANY. THE ADVISER, THROUGH ITS "SUPERVISED PERSONS", PROVIDES NON-DISCRETIONARY INVESTMENT ADVICE TO THE COMPANY UNDER THE
MSA CONCERNING THE ACQUISITION OF SUBSIDIARIES. "MANAGEMENT AND ADMINISTRATIVE" SERVICES PROVIDED TO THE COMPANY UNDER THE MSA
IS NOT "INVESTMENT ADVICE". THE COMPANY AND THE TRUST ARE PUBLIC REPORTING COMPANIES UNDER THE EXCHANGE ACT WITH TRUST
SECURITIES LISTED ON THE NYSE. ON MAY 7, 2025, THE COMPANY AND TRUST ISSUED A PRESS RELEASE (THE "PRESS RELEASE") AND FILED A FORM 8-
K DISCLOSING NON-RELIANCE ON ITS FINANCIAL STATEMENTS FOR FISCAL 2024 AMID AN ONGOING INTERNAL INVESTIGATION INTO ITS SUBSIDIARY,
LUGANO HOLDING, INC. THE INVESTIGATION, LED BY OUTSIDE COUNSEL AND A FORENSIC ACCOUNTING FIRM, IS ONGOING BUT HAS PRELIMINARILY
IDENTIFIED IRREGULARITIES IN LUGANO'S NON-CODI FINANCING, ACCOUNTING, AND INVENTORY PRACTICES. EFFECTIVE MAY 7, 2025, LUGANO'S
FOUNDER AND CEO, MOTI FERDER, RESIGNED FROM ALL OF HIS POSITIONS AT LUGANO AND WILL NOT RECEIVE ANY SEVERANCE COMPENSATION. THE
PROCEEDING IS RELATED TO THE EVENTS DISCLOSED IN THE PRESS RELEASE. THE ADVISORY AFFILIATES WHO ARE DEFENDANTS IN THE PROCEEDING
INTEND TO DEFEND THEMSELVES AGAINST THE ALLEGATIONS WHICH THEY BELIEVE ARE WITHOUT MERIT CONCERNING SUCH ADVISORY AFFILIATES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE
CRD
Number:
168422
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COMPASS GROUP
MANAGEMENT LLC
(For individuals, Last, First,
Middle)
CRD
Number:
8111526
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Keller, Stephen, Andrew
(For individuals, Last, First,
Middle)
CRD
Number:
2725502
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SABO, ELIAS, JOSEPH
(For individuals, Last, First,
Middle)
CRD
Number:
5216342
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FAULKINGHAM, RYAN, JAMES
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
TODD AUGENBAUM, INDIVIDUALLY, AND ON BEHALF OF ALL OTHER SIMILARLY SITUATED, AS PLAINTIFF
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
CIVIL MONEY DAMAGES
3.
Filing Date of Court Action (MM/DD/YYYY):
05/12/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 

5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
FILED IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA (CASE NO. 8:25-CV-01003)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE CIVIL ACTION IS A CLASS ACTION FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS. THE ALLEGATIONS ARE FOR VIOLATION BY THE
DEFENDANTS OF: (I) OF SECTION 10(B) OF SECURITIES EXCHANGE ACT OF 1934, AS AMENDED ("EXCHANGE ACT") AND SEC RULE 10B-5 THEREUNDER,
AND (II) SECTION 20(A) OF THE EXCHANGE ACT
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
05/22/2025
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
THE ADVISER AND ITS ADVISORY AFFILIATES NAMED HEREIN WERE NAMED AS DEFENDANTS IN A CIVIL PROCEEDING AGAINST COMPASS DIVERSIFIED
HOLDINGS (THE "TRUST") AND COMPASS GROUP DIVERSIFIED HOLDINGS, LLC (THE "COMPANY") (THE TRUST AND COMPANY TOGETHER ARE REFERRED
TO AS "CODI"). THE COMPANY IS A CLIENT OF THE ADVISER PURSUANT TO A MANAGEMENT SERVICES AGREEMENT ("MSA") PURSUANT TO WHICH THE
ADVISER AND ITS EMPLOYEES PROVIDE MANAGEMENT SERVICES AND OTHER ADMINISTRATIVE SUPPORT SERVICES, INCLUDING THE SECONDMENT OF
ELIAS J. SABO AND STEPHEN KELLER AND HIS PREDECESSOR RYAN J. FAULKINGHAM, TO THE COMPANY. THE ADVISER, THROUGH ITS "SUPERVISED
PERSONS", PROVIDES NON-DISCRETIONARY INVESTMENT ADVICE TO THE COMPANY UNDER THE MSA CONCERNING THE ACQUISITION OF
SUBSIDIARIES. "MANAGEMENT AND ADMINISTRATIVE" SERVICES PROVIDED TO THE COMPANY UNDER THE MSA IS NOT "INVESTMENT ADVICE". THE
COMPANY AND THE TRUST ARE PUBLIC REPORTING COMPANIES UNDER THE EXCHANGE ACT WITH TRUST SECURITIES LISTED ON THE NYSE. ON MAY 7,
2025, THE COMPANY AND TRUST ISSUED A PRESS RELEASE (THE "PRESS RELEASE") AND FILED A FORM 8-K DISCLOSING NON-RELIANCE ON ITS
FINANCIAL STATEMENTS FOR FISCAL 2024 AMID AN ONGOING INTERNAL INVESTIGATION INTO ITS SUBSIDIARY, LUGANO HOLDING, INC. THE
INVESTIGATION, LED BY OUTSIDE COUNSEL AND A FORENSIC ACCOUNTING FIRM, IS ONGOING BUT HAS PRELIMINARILY IDENTIFIED IRREGULARITIES
IN LUGANO'S NON-CODI FINANCING, ACCOUNTING, AND INVENTORY PRACTICES. EFFECTIVE MAY 7, 2025, LUGANO'S FOUNDER AND CEO, MOTI
FERDER, RESIGNED FROM ALL OF HIS POSITIONS AT LUGANO AND WILL NOT RECEIVE ANY SEVERANCE COMPENSATION. THE PROCEEDING IS RELATED
TO THE EVENTS DISCLOSED IN THE PRESS RELEASE. THE ADVISER AND THE ADVISORY AFFILIATES WHO ARE DEFENDANTS IN THE PROCEEDING INTEND
TO DEFEND THEMSELVES AGAINST THE ALLEGATIONS WHICH THEY BELIEVE ARE WITHOUT MERIT CONCERNING THE ADVISER AND SUCH ADVISORY
AFFILIATES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.

Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
8111526
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Keller, Stephen, Andrew
(For individuals, Last, First,
Middle)
CRD
Number:
2725502
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SABO, ELIAS, JOSEPH
(For individuals, Last, First,
Middle)
CRD
Number:
2936230
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MACIARIELLO, PATRICK, A
(For individuals, Last, First,
Middle)
CRD
Number:
5216342
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FAULKINGHAM, RYAN, JAMES
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to

the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
NICOLAS MORENO, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, AS PLAINTIFF
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
CIVIL MONEY DAMAGES
3.
Filing Date of Court Action (MM/DD/YYYY):
05/12/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
FILED IN UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT (CASE NO. 3:25-CV-00758)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE CIVIL ACTION IS A CLASS ACTION FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS. THE ALLEGATIONS ARE FOR VIOLATION BY THE
DEFENDANTS OF: (I) OF SECTION 10(B) OF SECURITIES EXCHANGE ACT OF 1934, AS AMENDED ("EXCHANGE ACT") AND SEC RULE 10B-5 THEREUNDER,
AND (II) SECTION 20(A) OF THE EXCHANGE ACT.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
06/05/2025
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must

fit within the space provided). 
THE SUPERVISORY AFFILIATES OF THE ADVISER NAMED IN THIS DRP WERE INCLUDED AS DEFENDANTS IN A CIVIL PROCEEDING AGAINST COMPASS
GROUPDIVERSIFIED HOLDINGS, LLC (THE "COMPANY"). (THE COMPANY TOGETHER WITH COMPASS DIVERSIFIED HOLDINGS (THE "TRUST") ARE
REFERRED TO AS "CODI"). THE COMPANY IS A CLIENT OF THE ADVISER PURSUANT TO A MANAGEMENT SERVICES AGREEMENT ("MSA") PURSUANT TO
WHICH THE ADVISER AND ITS EMPLOYEES PROVIDE MANAGEMENT SERVICES AND OTHER ADMINISTRATIVE SUPPORT SERVICES, INCLUDING THE
SECONDMENT OF ELIAS J. SABO AND STEPHEN KELLER AND HIS PREDECESSOR RYAN J. FAULKINGHAM, TO THE COMPANY. THE ADVISER, THROUGH ITS
"SUPERVISED PERSONS", PROVIDES NON-DISCRETIONARY INVESTMENT ADVICE TO THE COMPANY UNDER THE MSA CONCERNING THE ACQUISITION OF
SUBSIDIARIES. "MANAGEMENT AND ADMINISTRATIVE" SERVICES PROVIDED TO THE COMPANY UNDER THE MSA IS NOT "INVESTMENT ADVICE". THE
COMPANY AND THE TRUST ARE PUBLIC REPORTING COMPANIES UNDER THE EXCHANGE ACT WITH TRUST SECURITIES LISTED ON THE NYSE. ON MAY 7,
2025, THE COMPANY AND TRUST ISSUED A PRESS RELEASE (THE "PRESS RELEASE") AND FILED A FORM 8-K DISCLOSING NON-RELIANCE ON ITS
FINANCIAL STATEMENTS FOR FISCAL 2024 AMID AN ONGOINGINTERNAL INVESTIGATION INTO ITS SUBSIDIARY, LUGANO HOLDING, INC. THE
INVESTIGATION, LED BY OUTSIDE COUNSEL AND A FORENSIC ACCOUNTING FIRM, IS ONGOING BUT HAS PRELIMINARILY IDENTIFIED IRREGULARITIES
IN LUGANO'S NON-CODI FINANCING, ACCOUNTING, AND INVENTORYPRACTICES. EFFECTIVE MAY 7, 2025, LUGANO'S FOUNDER AND CEO, MOTI FERDER,
RESIGNED FROM ALL OF HIS POSITIONS AT LUGANO AND WILL NOT RECEIVE ANY SEVERANCE COMPENSATION. THE PROCEEDING IS RELATED TO THE
EVENTS DISCLOSED IN THE PRESS RELEASE. THE ADVISORY AFFILIATES WHO ARE DEFENDANTS IN THE PROCEEDING INTEND TO DEFEND THEMSELVES
AGAINST THE ALLEGATIONS WHICH THEY BELIEVE ARE WITHOUT MERIT CONCERNING SUCH ADVISORY AFFILIATES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
5216342
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FAULKINGHAM, RYAN, JAMES
(For individuals, Last, First,
Middle)
CRD
Number:
8111526
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Keller, Stephen, Andrew
(For individuals, Last, First,
Middle)
CRD
Number:
2725502
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SABO, ELIAS, JOSEPH
(For individuals, Last, First,

Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
AARON JONES, A STOCKHOLDER, PURPORTEDLY DERIVATIVELY ON BEHALF OF THE "COMPANY" INCLUDING COMPASS GROUP MANAGEMENT LLC.
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
CIVIL MONEY DAMAGES
3.
Filing Date of Court Action (MM/DD/YYYY):
06/05/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
FILED IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA (CASE NO. 2:25-CV-5098)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE CIVIL ACTION IS A PURPORTED STOCKHOLDER DERIVATIVE ACTION FOR BREACH OF FIDUCIARY DUTIES BY THE ADVISORY AFFILIATES AS
"DIRECTOR DEFENDANTS" AND/OR "OFFICER DEFENDANTS" AS DEFINED IN THE COMPLAINT AND VIOLATION BY THE DEFENDANTS OF SECTION 14(A)
OF SECURITIES EXCHANGE ACT OF 1934, AS AMENDED ("EXCHANGE ACT").
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
07/15/2025
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:

A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
A STOCKHOLDER IS BRINGING THIS PURPORTED DERIVATIVE ACTION ON BEHALF OF THE ADVISER, COMPASS DIVERSIFIED HOLDINGS (THE "TRUST")
AND COMPASS GROUP DIVERSIFIED HOLDINGS, LLC (THE "COMPANY") (THE TRUST AND COMPANY TOGETHER ARE REFERRED TO AS "CODI") AGAINST
ADVISORY AFFILIATES NAMED AS DEFENDANTS IN THEIR CAPACITY AS OFFICERS AND DIRECTORS OF CODI AND WITH RESPECT TO THEIR ROLES WITH
THE ADVISER. THE COMPANY IS A CLIENT OF THE ADVISER PURSUANT TO A MANAGEMENT SERVICES AGREEMENT ("MSA") PURSUANT TO WHICH THE
ADVISER AND ITS EMPLOYEES PROVIDE MANAGEMENT SERVICES AND OTHER ADMINISTRATIVE SUPPORT SERVICES, INCLUDING THE SECONDMENT OF
ELIAS J. SABO AND STEPHEN KELLER AND HIS PREDECESSOR RYAN J. FAULKINGHAM, TO THE COMPANY. THE ADVISER, THROUGH ITS "SUPERVISED
PERSONS", PROVIDES NON-DISCRETIONARY INVESTMENT ADVICE TO THE COMPANY UNDER THE MSA CONCERNING THE ACQUISITION OF
SUBSIDIARIES. "MANAGEMENT AND ADMINISTRATIVE" SERVICES PROVIDED TO THE COMPANY UNDER THE MSA IS NOT "INVESTMENT ADVICE". THE
COMPANY AND THE TRUST ARE PUBLIC REPORTING COMPANIES UNDER THE EXCHANGE ACT WITH TRUST SECURITIES LISTED ON THE NYSE. ON MAY 7,
2025, THE COMPANY AND TRUST ISSUED A PRESS RELEASE (THE "PRESS RELEASE") AND FILED A FORM 8-K DISCLOSING NON-RELIANCE ON ITS
FINANCIAL STATEMENTS FOR FISCAL 2024 AMID AN ONGOING INTERNAL INVESTIGATION INTO ITS SUBSIDIARY, LUGANO HOLDING, INC. THE
INVESTIGATION, LED BY OUTSIDE COUNSEL AND A FORENSIC ACCOUNTING FIRM, IS ONGOING BUT HAS PRELIMINARILY IDENTIFIED IRREGULARITIES
IN LUGANO'S NON-CODI FINANCING, ACCOUNTING, AND INVENTORY PRACTICES. EFFECTIVE MAY 7, 2025, LUGANO'S FOUNDER AND CEO, MOTI
FERDER, RESIGNED FROM ALL OF HIS POSITIONS AT LUGANO AND WILL NOT RECEIVE ANY SEVERANCE COMPENSATION. THE PROCEEDING IS RELATED
TO THE EVENTS DISCLOSED IN THE PRESS RELEASE. THE ADVISORY AFFILIATES WHO ARE DEFENDANTS IN THE PROCEEDING INTEND TO DEFEND
THEMSELVES AGAINST THE ALLEGATIONS WHICH THEY BELIEVE ARE WITHOUT MERIT CONCERNING SUCH ADVISORY AFFILIATES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
5216342
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FAULKINGHAM, RYAN, JAMES

(For individuals, Last, First,
Middle)
CRD
Number:
2936230
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MACIARIELLO, PATRICK, A
(For individuals, Last, First,
Middle)
CRD
Number:
2725502
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SABO, ELIAS, JOSEPH
(For individuals, Last, First,
Middle)
CRD
Number:
8111526
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Keller, Stephen, Andrew
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
KEVIN TAN, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
CIVIL MONEY DAMAGES
3.
Filing Date of Court Action (MM/DD/YYYY):
06/25/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
FILED IN UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA (CASE NO. 2:25-CV-5777)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 

THE CIVIL ACTION IS A CLASS ACTION FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS. THE ALLEGATIONS ARE FOR VIOLATION BY THE
DEFENDANTS OF: (I) OF SECTION 10(B) OF SECURITIES EXCHANGE ACT OF 1934, AS AMENDED ("EXCHANGE ACT") AND SEC RULE 10B-5 THEREUNDER,
AND (II) SECTION 20(A) OF THE EXCHANGE ACT
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
07/11/2025
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
THE ADVISER AND ITS ADVISORY AFFILIATES NAMED HEREIN WERE NAMED AS DEFENDANTS IN A CIVIL PROCEEDING AGAINST COMPASS DIVERSIFIED
HOLDINGS (THE "TRUST") AND COMPASS GROUP DIVERSIFIED HOLDINGS, LLC (THE "COMPANY") (THE TRUST AND COMPANY TOGETHER ARE REFERRED
TO AS "CODI"). THE COMPANY IS A CLIENT OF THE ADVISER PURSUANT TO A MANAGEMENT SERVICES AGREEMENT ("MSA") PURSUANT TO WHICH THE
ADVISER AND ITS EMPLOYEES PROVIDE MANAGEMENT SERVICES AND OTHER ADMINISTRATIVE SUPPORT SERVICES, INCLUDING THE SECONDMENT OF
ELIAS J. SABO AND STEPHEN KELLER AND HIS PREDECESSOR RYAN J. FAULKINGHAM, TO THE COMPANY. THE ADVISER, THROUGH ITS "SUPERVISED
PERSONS", PROVIDES NON-DISCRETIONARY INVESTMENT ADVICE TO THE COMPANY UNDER THE MSA CONCERNING THE ACQUISITION OF
SUBSIDIARIES. "MANAGEMENT AND ADMINISTRATIVE" SERVICES PROVIDED TO THE COMPANY UNDER THE MSA IS NOT "INVESTMENT ADVICE". THE
COMPANY AND THE TRUST ARE PUBLIC REPORTING COMPANIES UNDER THE EXCHANGE ACT WITH TRUST SECURITIES LISTED ON THE NYSE. ON MAY 7,
2025, THE COMPANY AND TRUST ISSUED A PRESS RELEASE (THE "PRESS RELEASE") AND FILED A FORM 8-K DISCLOSING NON-RELIANCE ON ITS
FINANCIAL STATEMENTS FOR FISCAL 2024 AMID AN ONGOING INTERNAL INVESTIGATION INTO ITS SUBSIDIARY, LUGANO HOLDING, INC. THE
INVESTIGATION, LED BY OUTSIDE COUNSEL AND A FORENSIC ACCOUNTING FIRM, IS ONGOING BUT HAS PRELIMINARILY IDENTIFIED IRREGULARITIES
IN LUGANO'S NON-CODI FINANCING, ACCOUNTING, AND INVENTORY PRACTICES. EFFECTIVE MAY 7, 2025, LUGANO'S FOUNDER AND CEO, MOTI
FERDER, RESIGNED FROM ALL OF HIS POSITIONS AT LUGANO AND WILL NOT RECEIVE ANY SEVERANCE COMPENSATION. THE PROCEEDING IS RELATED
TO THE EVENTS DISCLOSED IN THE PRESS RELEASE. THE ADVISER AND THE ADVISORY AFFILIATES WHO ARE DEFENDANTS IN THE PROCEEDING INTEND
TO DEFEND THEMSELVES AGAINST THE ALLEGATIONS WHICH THEY BELIEVE ARE WITHOUT MERIT CONCERNING THE ADVISER AND SUCH ADVISORY
AFFILIATES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
5216342
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FAULKINGHAM, RYAN, JAMES
(For individuals, Last, First,
Middle)
CRD
Number:
2725502
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SABO, ELIAS, JOSEPH
(For individuals, Last, First,
Middle)
CRD
Number:
8111526
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Keller, Stephen, Andrew
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
DENNIS KELLY, A STOCKHOLDER, PURPORTEDLY DERIVATIVELY ON BEHALF OF THE "COMPANY' INCLUDING COMPASS GROUP MANAGEMENT LLC
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
CIVIL MONEY DAMAGER

3.
Filing Date of Court Action (MM/DD/YYYY):
07/17/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
FILED IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA (CASE NO. 2:25-CV-6499)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE CIVIL ACTION IS A PURPORTED STOCKHOLDER DERIVATIVE ACTION FOR BREACH OF FIDUCIARY DUTIES BY THE ADVISORY AFFILIATES AS
"DIRECTOR DEFENDANTS" AND/OR "OFFICER DEFENDANTS" AS DEFINED IN THE COMPLAINT AND VIOLATION BY THE DEFENDANTS OF SECTION 14(A)
OF SECURITIES EXCHANGE ACT OF 1934, AS AMENDED ("EXCHANGE ACT").
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
08/06/2025
 Exact
 Explanation
If not exact, provide explanation:
COMPASS GROUP MANAGEMENT LLC ("CGM") WAS NOT OFFICIALLY SERVED IN THIS MATTER, HOWEVER ON AUGUST 6, 2025, CGM STIPULATED TO A
REQUESTED CONSOLIDATION OF THIS WITH A "COPYCAT" CASE: AARON JONES, DERIVATIVELY ON BEHALF OF COMPASS DIVERSIFIED HOLDINGS,
COMPASS GROUP DIVERSIFIED HOLDINGS LLC AND COMPASS GROUP MANAGEMENT, LLC, AS PLAINTIFFS VS. PARTIES INCLUDING ELIAS J SABO, RYAN.
J. FAULKINGHAM AND STEPHEN KELLER, AS DEFENDANTS (EACH INDIVIDUAL IS AN "ADVISORY AFFILIATE")
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
A STOCKHOLDER IS BRINGING THIS PURPORTED DERIVATIVE ACTION ON BEHALF OF THE ADVISER, COMPASS DIVERSIFIED HOLDINGS (THE "TRUST")
AND COMPASS GROUP DIVERSIFIED HOLDINGS, LLC (THE "COMPANY") (THE TRUST AND COMPANY TOGETHER ARE REFERRED TO AS "CODI") AGAINST
ADVISORY AFFILIATES NAMED AS DEFENDANTS IN THEIR CAPACITY AS OFFICERS AND DIRECTORS OF CODI AND WITH RESPECT TO THEIR ROLES WITH
THE ADVISER. THE COMPANY IS A CLIENT OF THE ADVISER PURSUANT TO A MANAGEMENT SERVICES AGREEMENT ("MSA") PURSUANT TO WHICH THE
ADVISER AND ITS EMPLOYEES PROVIDE MANAGEMENT SERVICES AND OTHER ADMINISTRATIVE SUPPORT SERVICES, INCLUDING THE SECONDMENT OF
ELIAS J. SABO AND STEPHEN KELLER AND HIS PREDECESSOR RYAN J. FAULKINGHAM, TO THE COMPANY. THE ADVISER, THROUGH ITS "SUPERVISED
PERSONS", PROVIDES NON-DISCRETIONARY INVESTMENT ADVICE TO THE COMPANY UNDER THE MSA CONCERNING THE ACQUISITION OF
SUBSIDIARIES. "MANAGEMENT AND ADMINISTRATIVE" SERVICES PROVIDED TO THE COMPANY UNDER THE MSA IS NOT "INVESTMENT ADVICE". THE
COMPANY AND THE TRUST ARE PUBLIC REPORTING COMPANIES UNDER THE EXCHANGE ACT WITH TRUST SECURITIES LISTED ON THE NYSE. ON MAY 7,
2025, THE COMPANY AND TRUST ISSUED A PRESS RELEASE (THE "PRESS RELEASE") AND FILED A FORM 8-K DISCLOSING NON-RELIANCE ON ITS
FINANCIAL STATEMENTS FOR FISCAL 2024 AMID AN ONGOING INTERNAL INVESTIGATION INTO ITS SUBSIDIARY, LUGANO HOLDING, INC. THE

INVESTIGATION, LED BY OUTSIDE COUNSEL AND A FORENSIC ACCOUNTING FIRM, IS ONGOING BUT HAS PRELIMINARILY IDENTIFIED IRREGULARITIES
IN LUGANO'S NON-CODI FINANCING, ACCOUNTING, AND INVENTORY PRACTICES. EFFECTIVE MAY 7, 2025, LUGANO'S FOUNDER AND CEO, MOTI
FERDER, RESIGNED FROM ALL OF HIS POSITIONS AT LUGANO AND WILL NOT RECEIVE ANY SEVERANCE COMPENSATION. THE PROCEEDING IS RELATED
TO THE EVENTS DISCLOSED IN THE PRESS RELEASE. THE ADVISORY AFFILIATES WHO ARE DEFENDANTS IN THE PROCEEDING INTEND TO DEFEND
THEMSELVES AGAINST THE ALLEGATIONS WHICH THEY BELIEVE ARE WITHOUT MERIT CONCERNING SUCH ADVISORY AFFILIATES.