Mitchell Capital Management Co (MCM) is a SEC registered investment adviser specializing in investment management for employee benefit plans, corporations, foundations, charitable organizations and individuals (trust, estates and IRAs). MCM may also act as a sub-advisor for accounts. MCM was founded in 1987 by Fred Mitchell. The current principal owners are Ken Green and Jonn Wullschleger. Other employee owners are Christen Dusselier, Phil Kernen, Barbara Roszel and Janet Rowe. For our clients, we invest in stocks (exchanged listed, over the counter and ADRs), fixed income securities (corporate bonds, municipal bonds, government bonds, CDs), ETFs and mutual funds. Our work combines modern technology with traditional concepts of security analysis. PORTFOLIO MANAGEMENT SERVICES MCM’s advisory services to separately managed accounts are customized based on the needs of each separate client’s account. MCM helps each client establish their own investment guidelines. The investment guidelines state what MCM will and will not do when managing the portfolio. Each client’s unique requirements are carefully reviewed and portfolios are systematically invested in securities that meet client requirements and our exacting standards of investment value. If a client holds certain securities prior to MCM’s management that they want to retain, they may be held in the “client managed” section of the portfolio. However, the client may set limitations in the Investment Guidelines specifying that certain securities purchased prior to MCM’s retention may not be sold. If this happens, MCM will place these securities in the client managed section of the portfolio. Also, the client may restrict MCM from purchasing certain securities they are not comfortable investing in. These requests are monitored by placing a trade restriction in the trading software system which is reviewed before every purchase is made. MCM prohibits speculative transactions. Other statements place limits on the types of assets and specifies asset quality standards that must be maintained in the portfolio. It is a clarifying process that creates objective standards for monitoring future investment progress. Retirement Rollover Conflicts of Interest: When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Being a fiduciary requires us to act in your best interest and not put our interest ahead of yours. Therefore, we:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put our financial interests ahead of yours when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that we give advice that is in your best interest;  Charge no more than is reasonable for our services; and  Give you basic information about conflicts of interest. A client, or prospective client, leaving an employer typically has four options

regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer's plan, if permitted, (ii) roll over the assets to the new employer's plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account ("IRA"), or (iv) cash out the account value (which could, depending upon the Retirement Investor's age, result in adverse tax consequences). If MCM accepts investment management responsibility for an IRA rollover, MCM will earn an advisory fee on the rolled over assets. MCM has adopted reasonable and prudent procedures to facilitate and document the consideration of the Retirement Investor's investment alternatives which requires an assessment of the existing plan and available options. As applicable, such assessment will evaluate the fees and expenses of each option, including whether the employer pays for some or all of the plan's administrative expenses, and the different levels of services and investments available under each option, among other considerations. No client, or prospective client, is under any obligation to rollover retirement plan assets to an account managed by MCM. FINANCIAL PLANNING SERVICES We offer comprehensive financial planning for our clients, included as part of the annual percentage of assets under management fee for our Investment Management services. The financial planning services we provide may be specific or standard in their preparation (unique to each client need). Topics included as part of financial planning services may include, but are not limited to, the following: 1) Retirement planning 2) Social Security 3) Education saving options 4) Debt management 5) Analysis of investments 6) Tax planning 7) Life events We will consult with the client to determine the client’s personal financial situation and goals. As well as analyze the client’s financial documentation. If applicable, we will review the client’s assets and liabilities, investment account(s), retirement assets, education funding, risk tolerance and any other areas that help give a full picture of the client’s financial health. We meet with the client to explain the plan and our recommendations. We make ourselves available to work with the client to implement the plan. The plan is updated to take into account changes in markets, tax laws, life events etc. The client is ultimately responsible for communicating changes so that we can provide the most accurate advice. The client is ultimately responsible for the implementation or rejection of our recommendations. The client is never obligated or required to implement our recommendations. SUB-ADVISOR SERVICES MCM has a sub-advisory relationship with various financial consultants and banks. MCM will contract with these unaffiliated institutions to provide discretionary portfolio management services to their advisory clients consistent with their client’s stated goals, objectives and risk tolerance. MCM currently does not participate in a wrap fee program. As of 12/31/23, MCM had $762.7 million in discretionary assets under management for 740 accounts. $729.9 million are assets on which we charge a fee and $32.8 million are assets that clients manage.