ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... iii ITEM 6 - SUPERVISION ............................................................................................................................... iii Lewis Capital Management Brochure Revised March 17, 2023 6 Description of Advisory Firm Lewis Capital Management, LLC (“LCM,” “we,” “our,” or “us”) was licensed as an investment adviser firm on July 20, 2000. Scott Craig Lewis, JD, CFA is the sole owner and Chief Compliance Officer. The firm is not publicly owned or traded and there are no indirect owners of the firm or intermediaries with any ownership interests. Fiduciary Duty Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty carries with it an obligation to act in the best interest of our clients pursuant to a relationship of trust and confidence. It encompasses a duty of care and a duty of loyalty. Duty of Care The duty of care includes, among other things: 1. the duty to provide advice that is in the best interest of the client; 2. the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades; and 3. the duty to provide advice and monitoring over the course of the relationship. The duty to provide advice suitable to each client based on a reasonable understanding of the client’s objectives is a critical component of the duty of care. Providing suitable advice includes making a reasonable inquiry into the client’s financial situation, investment experience, and financial goals and then updating this information as necessary throughout the course of the relationship to reflect the client’s changing objectives over time and adjusting the advice we provide to reflect any changed circumstances. When LCM has the responsibility to select broker-dealers to execute client trades in discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. In doing so, we consider the full range and quality of a broker’s services and so the determinative factor is not necessarily the lowest possible commission cost but whether the transaction represents the best qualitative execution. Moreover, we periodically and systematically evaluate the execution we receive on behalf of our clients. Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in the best interest of the client, taking into account the scope of the agreed relationship. This scope is indicated by the duration and nature of the services as outlined in each client’s advisory arrangement and extends to all personalized advice provided to clients. Duty of Loyalty LCM adheres to a duty of loyalty where we seek to serve the best interests of our clients and never subordinate the interests of our clients to our own. Simply put, LCM cannot place its own interests ahead of the interests of our clients. In observance of this duty, we must make full and fair disclosure to clients of all material facts relating to the advisory relationship. Further, we also seek to eliminate or at least expose through full and fair disclosure all conflicts of interest which might incline LCM, consciously or unconsciously, to render advice that is not disinterested. We Lewis Capital Management Brochure Revised March 17, 2023 7 believe that in order for disclosure to be full and fair, it should be sufficiently specific so that each client is able to understand the material fact or conflict of interest and make an informed decision whether to provide consent. Consequently, we provide this ADV 2A brochure to all prospective clients at or before entering into a contract so that they can use the information within to decide whether or not to enter into an advisory relationship. Advisory Services Offered LCM offers the following services to advisory clients: Investment Management Services LCM provides continuous and personal investment advice and manages clients’ portfolios on a discretionary basis. Investment advice is tailored to each client based on the individual client’s financial objectives, risk tolerances, and personal circumstances. Such investment advisory services are the only services offered by LCM. The advisory relationship is initiated with a series of consultation meetings or phone calls between Scott Lewis and the client wherein they discuss the client’s overall financial situation. Topics include a specific client’s investment objectives, risk tolerance, planning horizon, asset- class preferences, and LCM investment strategies. LCM then tailors an investment policy relying on client-supplied data. Once these initial sessions are completed, LCM presents verbally and/or in writing the investment plan designed specifically for the client’s managed portfolio. Clients are provided assistance in obtaining and completing the required paperwork to establish the necessary investment accounts. LCM manages a client’s portfolio primarily using individually researched and selected common stocks and fixed income securities, along with other publicly traded

investments such as exchange traded funds (ETFs). Asset-allocation decisions are based predominately on the client’s financial situation and risk tolerance, as well as on the current asset class attractiveness. In addition, LCM evaluates and manages for tax implications specific to the client. Cash will also be held in the portfolio for client liquidity needs or while awaiting investment opportunities. For the fixed-income portion of the portfolio, LCM generally holds corporate, government, agency, bank certificates and/or municipal securities, as appropriate to the client’s circumstances. LCM generally applies a “value” focus in selecting equities and does not attempt to engage in market timing. Stock investments are typically held for longer periods, and bonds are typically held to maturity. Portfolio turnover is low. Following is a summary of key investment philosophies and practices of LCM. LCM is value driven, investing in companies that we believe are trading significantly below their underlying value (undervalued), and over time will appreciate to reflect their legitimate worth. LCM uses quantitative computer screens, proprietary financial models, and qualitative judgments to located undervalued stocks that it believes have potential for long-term appreciation. LCM believes that diligent research is fundamental to prudent investment decisions. We look at each stock as if we are buying the company, not just a tradable security. LCM believes that by Lewis Capital Management Brochure Revised March 17, 2023 8 concentrating on our best 10 to 25 stock ideas, investment results can potentially be improved compared to spreading our research efforts over too wide a base. Asset allocation is an ongoing process based on open and consistent dialogue between the client and LCM. Proper asset allocation should reflect the client’s investment time horizon, risk tolerance, return expectations and income requirements. We believe that patient trading and low commissions can potentially help investment returns. LCM does not generally attempt to predict short and intermediate term moves of the market. Limitations on Investments In some circumstances, LCM’s advice may be limited to certain types of securities. Limitation by Plan Sponsor/Employer In the event LCM is managing assets within a retirement plan such as 401(k), 403(b), or other employer plan, LCM is limited to those investment providers and investment options chosen by the plan administrator. Similarly, when we provide services to participants in an employer- sponsored plan, the participant may be limited to investing in securities included in the plan’s investment options. Therefore, LCM can only make recommendations to the client from among the available options and will not recommend or invest the client’s account in other securities, even if there may be more suitable options elsewhere. Limitation by Client LCM may also limit advice based on certain client-imposed restrictions. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this Item below. Other Services and Limitations LCM does not provide tax or legal advice. It is the client’s responsibility to consult with tax advisors as needed. Unmanaged Assets At its discretion, LCM may offer securities trading activities for a client’s unmanaged assets within their account, acting as an intermediary between the client and the custodian. We do not generally provide investment advice regarding a client’s unmanaged assets or provide opinions as to the merits of any unmanaged securities. We also do not make any judgments as to the appropriateness of assumed risk or suitability of any unmanaged investment given the client’s situation. At our discretion, LCM offers this service in consideration of the client’s other accounts that we manage. Tailored Services and Client Imposed Restrictions LCM 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. LCM applies the 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 recommendations/investment selections may not be suitable if the client does not provide us with accurate and complete information. It is Lewis Capital Management Brochure Revised March 17, 2023 9 the client’s responsibility to keep LCM 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 LCM to buy or sell certain specific securities or security types in the account. LCM 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 Program We do not manage accounts as part of a wrap or bundled fee program. Assets Under Management As of December 31, 2022, LCM managed assets on a discretionary basis in the amount of $160,212,199.