BASE Management Company is an independent fiduciary investment management firm specializing in actively managed equity portfolios. BASE attempts to create real long run investment returns for clients BASE Management Company, ADV Brochure, 04/16/24, Page 3 of 10 by incurring risk economically in pursuit of that return.(See section 8) BASE was organized and has operated continuously since 1986. BASE provides discretionary investment supervisory services for US entities including individuals as well as trusts, charitable organizations and corporations. Investment supervisory service means that investment advice and investment management is provided on a continuous basis and is provided taking into account a client’s individual circumstances and needs, among other things. BASE provides these services in exchange for fees based on the asset values involved. Mr. Francis M. Hogle, III is President, CEO and majority owner of BASE. BASE has two other shareholders: Carolyn Frenkil and Patricia Hoffman. Mr. Hogle, born in 1944, graduated with a BS in Physics from Carnegie Institute of Technology in 1967. He has been a licensed professional in the securities business since 1973. There are no other licensed personnel and he is in charge of investment and compliance functions. BASE requires of its personnel securities knowledge, securities experience as well as a compatible investment philosophy. BASE does not accept non-discretionary accounts for an asset based fee, but it may charge an appropriate hourly fee. BASE does not have a minimum account size, per se. Client restrictions are an item for negotiation. When agreed to, such restrictions are applied on a best efforts basis. BASE will deal with a client only if, in the sole opinion of Mr. Hogle, it can reasonably provide the services that the account requires, and if, in the sole opinion of Mr. Hogle, that BASE and the prospective client can conduct a mutually beneficial relationship. BASE does not participate in wrap fee programs, in other words, BASE has no arrangements with brokerage firms or other advisors to manage client assets. BASE by its nature is a generalist. BASE selects and follows securities on its own and does not rely on others for those functions. Research of value to BASE lies in suggesting structures of analysis and relationships so that BASE can accomplish its own functions. BASE presently manages approximately $52.5 million on a discretionary basis and approximately $27.1 million on a non-discretionary basis. BASE claims compliance with the Global Investment Performance Standards (GIPS). The firm consists of all client assets of BASE that are both discretionary and fee paying, plus assets under BASE’s purview that are proprietary, related and (or) non-discretionary. BASE Management Company, ADV Brochure, 04/16/24, Page 4 of 10 4a. CONFLICTS OF INTEREST Because BASE’s investment philosophy is and has been supplied by Mr. Hogle, he and (or) related entities may own securities or may trade in securities that BASE clients own. BASE is a fiduciary adviser. While BASE attempts to eliminate conflicts of interest with clients by design in BASE’s business methods, a class of conflicts exists that cannot be eliminated. Questions of the size or of the existence of an account are clear examples of this. Because BASE charges an asset based fee, it has an interest in the answer. BASE is unaware of any conflicting business interests that might make its proxy voting interests different than those of its clients. (Please see item 17) BASE or Mr. Hogle have no arrangements with third parties (unrelated entities) to receive or pay compensation on, by, or as a result of BASE accounts (including soft dollar arrangements, execution rebates, and sub advisor arrangements) except as contained in an agreement between BASE and Fidelity Clearing and Custody Solutions. That agreement makes custody and execution services available to BASE’s clients. That agreement was made based on Mr. Hogle’s experience with and contacts within the Fidelity organization,

and was based on the inability of many clients to negotiate custody and execution arrangements for themselves that are both favorable to themselves and compatible with BASE’s need for electronic access to those accounts. While neither BASE nor Fidelity receives any direct compensation from each other as a result of that arrangement, certain aspects of Fidelity’s Wealth Central platform might be viewed as indirect compensation in one direction or the other if BASE relied upon them. BASE does not view these aspects to be significant, either to itself or to its clients. Clients are not required to use Fidelity and may direct custody and (or) execution in any manner they choose that is compatible with BASE’s access and (or) execution requirements respectively. (See, item 12) The following are common conflicts of interest that are not present in BASE’s business: 1.BASE does not participate in wrap fee programs. 2.BASE does not receive compensation beyond the agreed upon fees related to BASE clients. All of BASE’s revenue is from either client fees or investment returns on assets owned by BASE itself. 3.BASE does not charge performance based fees. (See, item 6) 4.BASE is not a broker-dealer and has no agreements with broker-dealers beyond the Fidelity agreement described above. (See also, items 12 and 15) 5.BASE has no business relationship with mutual funds, unit trusts, private investment companies, hedge funds, offshore funds, other financial advisors, financial planners, futures commission merchants, commodity pool operators, commodity trading advisors, insurance agencies, pension consultants, realtors, or sponsors of limited partnerships. 6.BASE does not engage in purchasing benefits for itself using client commissions (soft dollars). 7.BASE does not compensate for referrals. (See, item 14) 8.No partnership exists wherein related persons of BASE are general partners and BASE clients are investors. BASE Management Company, ADV Brochure, 04/16/24, Page 5 of 10 4b. PRIVACY BASE collects nonpublic personal information about clients from a number of sources. It collects information from clients and their designated agents, from consumer and business reporting agencies, from brokers, dealers, custodians and from public sources. BASE uses this information to form an opinion about suitability, to clear trades and generally to operate client accounts as investment adviser. BASE does not disclose nonpublic personal information about clients to anyone except as permitted by law or as specifically directed by those clients. If a client decides to close an account, or become an inactive customer, BASE will continue to adhere to the same privacy policy relative to that account as described herein. Internally, BASE restricts access to client personal and account information to those employees who need to know that information so that BASE can accomplish its fiduciary responsibilities on its clients’ behalf. If Mr. Hogle should end his association with BASE, both Mr. Hogle and BASE would be in possession of client nonpublic personal information, subject in both cases to the privacy policy described herein. BASE maintains reasonable physical, electronic and procedural safeguards to guard client nonpublic personal information. As a matter of law, BASE may receive and share such personal information from and with brokers, dealers, custodians, regulators, court systems in any relevant jurisdiction, and specified interested parties on a need to know basis without specific authority from clients. BASE and its employees will need written authorization in order to communicate nonpublic personal or financial information to other client agents such as a CPA, a lawyer or other business or personal contacts with whom clients would like BASE to share. BASE is not adverse to using electronic means of communication; however, electronic communication is not private. BASE will need specific written authority from clients in order to send sensitive information to them or to their designated agents via electronic means.