A. Description of the Advisory Firm 10th Mountain, LLC (the “Company”) is an Ohio Limited Liability Company (“LLC”) and was formed as a Registered Investment Advisor in October 2016. The Company’s principal place of business is located in Galena, Ohio. The President, Chief Compliance Officer and principal owner of the Company is Tomislav (“Tom”) B. Mitevski. Mr. Mitevski is licensed as an Investment Advisor Representative for the Company. 10th Mountain, LLC does not have a parent company or intermediate subsidiaries. The Company’s principal business is to provide investment advice and portfolio management services to its Clients who are typically high net worth individuals and families. B. Types of Advisory Services The Company takes a holistic approach to investment management services across multiple asset classes. 10th Mountain, LLC provides fixed income and public equities Portfolio Management Services to its Clients on a Discretionary basis and assists its Clients with the selection of other advisers/outside money managers. 10th Mountain utilizes an independent contractor—Frank Wojcik—to assist in providing portfolio management to its clients. At the inception of a Client relationship and on an ongoing basis, the Company determines and maintains either an Investment Objectives & Risk Tolerance Questionnaire or Investment Policy for each Client. Both the Questionnaire and Investment Policy are customized and aligned to each Client’s investment objectives, risk appetite, lifestyle needs and long-term wealth creation and wealth transfer goals. C. Client Tailored Services and Client Imposed Restrictions Clients may impose restrictions on investing in certain securities or types of securities. If a client imposes restrictions, these restrictions become a part of the investment guidelines which will be included as part of our management agreement with a Client. The Client’s account will be managed within these confines. Clients

should be aware that certain restrictions can limit our ability to act, and as a result, the Account’s performance may differ from and may be lower than that of other Accounts that have not limited the Company’s discretion. Depending on the particular investment portfolio and/or investment strategy, 10th Mountain, LLC employs a variety of security analysis methods including charting, fundamental economic data, trend and technical market indicators, and cyclical analysis. We also consult a wide range of information to analyze and execute investment strategies, such as: financial newspapers and magazines, various internet services, inspection of corporate activities, third-party research materials, corporate rating services, timing services, annual reports, prospectuses, regulatory filings, and press releases. D. Wrap-Fee Accounts 10th Mountain, LLC does not engage in a wrap-fee program. By definition, a wrap-fee program bundles or wraps investment advice, custody and execution services under one contract for a single fee. Generally, these programs involve one or more investment advisors and a broker-dealer that provide the Client with portfolio management and asset-allocation services, maintain custody of the Client’s funds and securities and execute Client securities transactions. Clients pay an annual or quarterly fixed fee based on the amount of assets under management rather than paying individual separate fees for each transaction, and the price includes brokerage commissions based on the amount or type of securities transactions executed for a given account. E. Assets Under Management 10th Mountain, LLC manages its Clients’ assets on a discretionary and non-discretionary basis. This is the Company’s Annual Updating Amendment for fiscal year ending December 31, 2023, and as of the date of this filing, the Company manages $410,653,320 in assets on a discretionary basis and $0.00 in assets on a non- discretionary basis.