Advisory Business The Advisor and Relying Adviser Minerva Advisors, LLC (“the Advisor”) provides investment advisory services to clients through separately managed accounts (the “separate accounts”) and to the Minerva Group, L.P. (“Fund”). The Advisor was formed on November 7, 2002 to provide investment advisory services. The Fund was formed to pursue certain investment strategies including, but not limited to, investment in equity securities of publicly traded U.S. micro-cap value companies and small-cap value companies. The Advisor and the Fund began operations on February 1, 2003. An affiliated entity serves as general partner of the Fund (the “General Partner”). The SPV was formed in February 2022 to facilitate an investment in a pink sheet-listed company. Minerva Advisors, LLC is affiliated through common ownership with Minerva 1894 GP, LLC, formed in 2022, which acts as a relying adviser (“Relying Adviser”) with respect to a special purpose vehicle (“SPV”) to facilitate an equity investment in a single pink sheet company on behalf of certain investors. This brochure describes the aggregate business practices of such affiliated entities, which operate a single advisory business filing a single Form ADV in reliance on U.S. Securities and Exchange Commission (“SEC”) guidance and are referred to throughout this Brochure by the following interchangeable terms: “Minerva” and “Advisor.” David P. Cohen is the manager and sole member of Minerva Advisors, LLC and owns 100% of its membership interests. Mr. Cohen has over 35 years of investment management experience, primarily in investments in small and micro-cap equity securities. David P. Cohen and Matthew Schaenen are members of Relying Adviser, Minerva 1894 GP, LLC, and together own 100% of its membership interests. In November 1988, Mr. Cohen founded Athena Capital Management, Inc. (“Athena”). Athena provided investment and advisory services to high-net-worth individuals. Mr. Cohen served as President of Athena and held 81.7% of the common stock of Athena. On December 31, 2011, Athena merged with and into the Advisor. Following the merger, client accounts formerly managed by Athena are now managed by the Advisor. The principal executive offices of the Advisor and its affiliated entities are located at 50 Monument Road, Suite 201, Bala Cynwyd, PA 19004. As of December 31, 2023, the Advisor had approximately $296,546,892 of assets under management on a discretionary basis and $6,839,807 of assets under management on a non- discretionary basis. Advisory Services Separate Accounts The Advisor provides discretionary investment advisory services through separately managed account arrangements pursuant to advisory contracts, which incorporate investment guidelines and restrictions. Advisory contracts typically are negotiated to meet the specific needs of a particular client. Generally, the Advisor’s investment strategy for the separate accounts is focused on small cap value investing in equity securities; however, this strategy is, when appropriate, tailored for different client needs, objectives, and risk tolerances, which may change from time to time, and also may vary depending on market conditions. Currently, the Advisor’s separate account clients are pursuing a long-term growth strategy. Qualified clients may engage the Advisor to manage a concentrated portfolio of securities. A separate account client is permitted to impose reasonable restrictions in writing on the Advisor’s ability to invest in certain securities. These investment restrictions may prohibit the purchase by the Advisor, for the benefit of the separate account, of individual securities or impose sector restrictions on the Advisor for the benefit of the separate account. The Advisor will

review any investment restrictions to determine whether they are reasonable. In the case of restrictions involving categories of securities, the Advisor also will determine the specific securities that will be included in the restricted category. Currently, the Advisor will consider accepting a very limited number of separate accounts in excess of $3 million. The Fund The Advisor provides investment management services to the Fund pursuant to an investment management agreement (the “Investment Management Agreement”) between the Advisor and the General Partner and the Fund, dated December 31, 2002. Under the Investment Management Agreement, the General Partner delegates to the Advisor all of its authority under the Fund’s limited partnership agreement (the “Partnership Agreement”) to manage and operate the Fund and formulate investment policy. The Investment Management Agreement requires the Advisor to direct the investments of the Fund, subject to and in accordance with the Fund’s investment objectives and limitations provided in the Partnership Agreement and the PPM. Interests in the Fund are offered exclusively to individuals who qualify as “accredited investors” under Regulation D promulgated under the Securities Act of 1933, as amended (the “1933 Act”), and “qualified clients” as such term is defined under the Advisers Act. The Fund is not required to register with the SEC as an investment company in accordance with the exemption set forth in Section 3(c)(1) of the Investment Company Act of 1940, as amended. Investment strategies and guidelines are not tailored to the individualized needs of any particular investor in the Fund. Other than the restrictions set out in the Investment Management Agreement, investors in the Fund are not permitted to impose restrictions on the Advisor’s ability to invest in certain securities or types of securities. The primary investment strategy of the Fund is making investments in equity securities of publicly traded U.S. micro-cap value companies and small cap value companies. The Fund is authorized to purchase debt securities, debt obligations and derivative securities of such companies. While the Advisor will seek to manage a diversified portfolio for the Fund, the Fund has no specific policy or guideline regarding diversification. As a result, the Fund’s investments may be concentrated in a few industries, companies, or geographic regions. Investments in the separate accounts and the Fund involve significant risks and should be regarded as long-term in nature, forming only one portion of an investor’s diversified investment portfolio. For further information on the Advisor’s investment methods, please refer to Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. The SPV An affiliate of the Advisor, Minerva 1894 GP, LLC, is deemed to be a Relying Adviser, providing investment management services to the SPV pursuant to an Agreement of Limited Partnership. Interests in the SPV were offered exclusively to individuals who qualify as “accredited investors” under Regulation D promulgated under the Securities Act of 1933, as amended (the “1933 Act”), and “qualified clients” as such term is defined under the Advisers Act. The SPV is not required to register with the SEC as an investment company in accordance with the exemption set forth in Section 3(c)(1) of the Investment Company Act of 1940, as amended. The SPV was formed to facilitate an equity investment in a single company on behalf of certain investors and is not currently accepting new investors. As a result, the SPV is not a diversified portfolio, and therefore an investment in the SPV involves significant risk and should be regarded as long term in nature, forming only one portion of an investor’s diversified investment portfolio.