Description of Advisory Firm Fairbanks Capital Management, Inc. (“FCM,” “we,” “our,” or “us”), formerly Quality Growth Management, Inc., is registered with the United States Securities and Exchange Commission as a Registered Investment Adviser. We were founded in Rancho Santa Fe, California, on January 2, 1996 by Steven L. Ré, CFA, who continues to own our company. Advisory Services Offered Investment Management Services Our objective is simple: to accumulate wealth through diligent long-term investing in equities and fixed income. We are purely discretionary managers. We determine when, where, how and why to purchase and or sell securities. Clients are required to maintain their own custodial relationship with a brokerage firm or bank. FCM will primarily utilize the following investment types when making investment purchases in client accounts: 1. Equity securities, such as stocks and foreign securities listed on US exchanges (ADRs) and/or foreign exchanges (ordinaries) 2. Municipal securities 3. Money market funds and cash 4. Master limited partnerships (MLPs) Additionally, FCM’s investment selections, depending on the individual investment objectives and needs of the client may include: 1. Fixed income securities, such as corporate bonds, commercial paper, and certificates of deposit (CDs) FCM may also occasionally utilize additional types of investments if they are appropriate to address the individual needs, goals, and objectives of the client or in response to client inquiry. FCM may offer investment advice on any investment held by the client at the start of the advisory relationship. We describe the material investment risks for many of the securities that we utilize under the heading Specific Security Risks in Item 8 below. We discuss our discretionary authority below under Item 16 - Investment Discretion. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below. We describe the fees charged for investment management services below under Item 5 - Fees and Compensation. Financial Planning Services FCM does

not generally provide comprehensive financial planning services, but we may offer financial planning related services as part of our overall advisory services. These services may involve providing advice to clients regarding the investment/management of financial resources based upon an analysis of their individual needs. However, services do not include preparation of any written financial plan, or any income tax, gift, or estate tax returns, or preparation of any legal documents. FCM does not receive separate compensation for financial planning related services. Tailored Services and Client Imposed Restrictions FCM manages client accounts based on the investment strategy the client chooses, as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. FCM applies the selected strategy for each client, based on the client’s individual circumstances and financial situation. We make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. Our investment selections may not be suitable if the client does not provide us with accurate and complete information. It is the client’s responsibility to keep FCM informed of any changes to their investment objectives or restrictions. Clients may also request other restrictions on the account, such as when a client needs to keep a minimum level of cash in the account or does not want FCM to buy or sell certain specific securities or security types in the account. FCM reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Wrap Fee Programs FCM does not manage accounts as part of a wrap or bundled fee program. Assets Under Management FCM manages client assets in discretionary and non- discretionary accounts on a continuous and regular basis. As of 12/31/2023, FCM has $339,014,041 in discretionary assets and $3,324,285 in non- discretionary assets with the total amount of assets under our management was $342,338,326.