GLOBAL VALUE INVESTMENT CORP.

Description of Firm Global Value Investment Corporation (“GVIC”) is a Delaware corporation offering investment research and advisory services to a variety of clients. GVIC began offering investment research and advisory services in 2007. Jeffrey R. Geygan, Chairman of the Board of Directors, is the controlling shareholder. James P. Geygan serves as the Chief Executive Officer and President. The firm is headquartered in Milwaukee, Wisconsin. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our investment advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to GVIC, and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. We offer investment management services through a wrap fee program (the "Program") as described in this wrap fee program brochure to prospective and existing clients. We are the portfolio manager to, and sponsor of, the Program. A wrap fee program is a type of investment program that provides you with access to our investment management services for a single fee that includes administrative fees, management fees, and commissions. If you participate in the Program, you will pay our firm a single fee, which includes our investment management fees, certain transaction costs, and custodial and administrative costs. You are not charged separate fees for the respective components of the total services, except as detailed in this Form ADV Part 2 – Appendix 1. The overall cost you will incur if you participate in the Program may be higher or lower than you might incur by separately purchasing the types of securities available in the Program. Prior to becoming a client under the Program, you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid. Investment Management Services We offer discretionary investment management services to high-net-worth individuals and other retail clients. We begin by conducting a complimentary initial consultation, during which pertinent information about your financial circumstances, goals, and objectives is collected. The information collection process typically addresses present and anticipated assets and liabilities, including investments, savings, and retirement or other employee or employer benefits. The primary objective of this process is for us to assist you in developing a strategy for the successful management of income, assets, and liabilities to meet your financial goals and objectives. Once your financial circumstances are determined, a portfolio is established and the investments within the portfolio are managed according to one or more investment strategies developed by our firm. These investment strategies are designed for clients with varying degrees of risk tolerance ranging from conservative to aggressive. Clients whose assets are invested in such investment strategies may set restrictions on the specific types of securities, holdings, or allocations within the strategy; in such cases, this may prevent a client from investing in certain investment strategies that are offered by GVIC. Our investment management services require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment management services agreement you sign with our firm and any applicable trading authorization documents. Assets for Program accounts are held at Charles Schwab & Co., member FINRA/SIPC, an unaffiliated SEC-registered broker-dealer, as custodian (the “Qualified Custodian”). The Qualified Custodian also acts as an executing broker/dealer for most transactions placed in Program accounts and provides other administrative services as described throughout this brochure. To compare the cost of the Program with non-wrap fee investment management services, you should consider the frequency of trading activity associated with our investment

strategies and the brokerage commissions charged by the Qualified Custodian and the advisory fees charged by investment advisers. Changes in Your Financial Circumstances In providing the contracted services, we are not required to verify any information we receive from you or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on the information you provide. Furthermore, unless you indicate to the contrary, we shall assume that there are no restrictions on our services, other than to manage your account in accordance with your designated investment objectives, risk tolerance, and time horizon. It is your responsibility to promptly notify us if there are ever any changes in your financial situation, investment objectives, risk tolerance, or time horizon for the purpose of reviewing, evaluating, and/or revising our previous recommendations and services. Investment Management Services Fee We charge an annual "wrap fee" for participation in the Program based on a percentage of the assets in your account. You are not charged separate fees for the different components of the services provided by the Program, except as detailed in this Form ADV Part 2 – Appendix 1. Our firm pays all trade expenses for trades placed on your behalf. Our Program fee includes our fee for management of your assets and the Qualified Custodian’s transaction or execution costs. Assets in your accounts are included in the fee assessment unless specifically identified in writing for exclusion. In special circumstances, and in our sole discretion, we may negotiate a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention, etc.). Our fee for investment management services is based on a percentage of the assets in your account and is set forth in the following annual fee schedule and break points. This fee schedule is negotiable.

TIERED FEE SCHEDULE Account Value

Annual Fee

$0

-

$500,000

1.50%

$500,000

-

$1,000,000

1.25%

$1,000,000

-

$5,000,000

1.00%

$5,000,000+

0.75%

Our annual investment management fee is billed and payable quarterly, in advance, based on the market value of the assets in your account at the beginning of each billing period, including any cash or cash-equivalent securities (such as balances held in a money market account). If the investment management services agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro-rata basis, which means that the advisory fee is payable in proportion to the number of days remaining in the quarter for which you are a client. Assets exceeding $20,000 deposited into your account during any quarter will be charged a prorated quarterly fee based upon the number of days remaining in the quarter. No adjustment shall be made to the quarterly fees for changes in the market value of securities held in your account during the calendar quarter. A pro-rata fee refund shall be made if assets valued at $20,000 or more are withdrawn from your account during the quarter. We may amend these fees by providing 30 days’ advance notice. At our discretion, we may combine the account values of family members living in the same household, or other related account owners, to determine the applicable advisory fee based on asset break points as listed above. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in you paying a reduced advisory fee based on the available break points in our fee schedule listed above. As a client, you should be aware that the wrap fee charged by our firm may be higher or lower than those charged by others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower or higher rates. A client may be able to obtain some or all the types of services available through the Program on an individual basis through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees shown above. Performance-Based Fees We do not charge performance fees on assets in the Program. Withdrawal of Assets You may withdraw account assets by providing notice to our firm in accordance with the terms of the Investment Management Services Agreement executed in connection with participation in the Program (the “Agreement”), and subject to the usual and customary securities settlement procedures. However, we design our portfolios as long-term investments, and asset withdrawals may impair the achievement of your specific investment objectives. Payment of Fees We will deduct our fee directly from your account through the Qualified Custodian. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the Qualified Custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy.

Termination of Advisory Relationship You may terminate the Agreement upon 30 days' written notice to our firm. You will incur a pro-rata charge for services rendered prior to the termination of the wrap fee program agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have prepaid advisory fees that we have not yet earned, you will receive a prorated refund of those unearned fees. Upon termination of accounts held at the Qualified Custodian, the Qualified Custodian will deliver securities and funds held in the account per your instructions unless you request that the account be liquidated. After the Agreement has been terminated, transactions are processed at the prevailing brokerage rates/fees. You become responsible for monitoring your own assets and our firm has no further obligation to act upon or to provide advice with respect to those assets. Wrap Fee Program Disclosures

The benefits under a wrap fee program depend, in part, upon the size of the account, the management fee charged, and the number of transactions likely to be generated in the account. For example, a wrap fee program may not be suitable for accounts with little trading activity. To evaluate whether the Program is suitable for you, you should compare the Program fee and any other costs of the Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and other execution costs, and custodial services comparable to those provided under the Program. In considering the investment programs described in this brochure, you should be aware that participating in a wrap fee program may cost more or less than the cost of purchasing advisory, brokerage, and custodial services separately from other advisers or broker-dealers. Our firm and associated persons receive compensation as a result of your participation in the Program. This compensation may be more than the amount our firm or the associated persons would receive if you paid separately for investment advice, brokerage, and other services. Accordingly, a conflict of interest exists because our firm and the associated persons have a financial incentive to recommend the Program. Similar advisory services may be available from other registered investment advisers for lower fees.

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We offer investment management services to individuals (other than high-net-worth individuals), high-net-worth individuals, pooled investment vehicles (other than investment companies and business development companies), pension and profit-sharing plans (but not the plan participants or government pension plans), charitable organizations, other investment advisers, and corporations or other businesses not listed above. In general, we require a minimum of $1,000,000 under our management to open and maintain an investment management relationship. At our discretion, we may waive this minimum relationship size requirement. In general, we require a minimum of $5,000,000 under our management to offer sub-advisory services or thirdparty advisory services to registered investment advisers. At our discretion, we may waive this minimum relationship size requirement. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum.

Without restriction, you should contact our firm or your advisory representative directly with any questions regarding your Program account. You should contact your advisory representative with respect to changes in your investment objectives, risk tolerance, or requested restrictions placed on the management of your Program assets.

To provide the Program services, we will share your private information with the Qualified Custodian. We may also provide your private information to mutual fund companies and/or private managers as needed. We will only share the information necessary to carry out our obligations to you in servicing your account. We share your personal account data in accordance with our privacy policy as described below.

We are the portfolio manager to, and sponsor of, the Program. Refer to Item 4. Services, Fees, and Compensation for additional disclosures on costs associated with your participation in the Program. Methods of Analysis, Investment Strategies, and Risk of Loss GVIC uses the methods of analysis described below when making recommendations for clients. This, however, should not be understood to limit in any way GVIC's investment activities. GVIC can offer any advisory services, engage in any investment strategy, and make any investment, including any not described in this brochure, that GVIC considers appropriate, subject to each client's investment objectives and guidelines. Fundamental Analysis – Fundamental analysis involves evaluation of an issuer’s financial condition and competitive position. GVIC analyzes an issuer's financial condition, assets, liabilities, earnings characteristics and capacity, products and services, the capabilities of management, and its position among competitors and in its respective industry. GVIC incorporates a wide variety of informational sources in its analysis. Security analysis typically begins with examination of an issuer’s regulatory filings with the United States Securities and Exchange Commission (or similar filing with equivalent regulatory bodies in an issuer’s respective jurisdiction), including Form 10-Q, Form 10-K, Form 8-K, Form 6-K, Form 20-F, Schedule 14A, or other offering documents or memoranda filed by the issuer, as well as Schedule 13D, Schedule 13D, Form 3, Form 4, Form 5, or other ownership disclosures, financial publications, newspapers and magazines, research materials prepared by others, corporate/credit rating services reports, annual reports, and other sources. GVIC may purchase various sources of research and information or use sources or information that have been developed over years of experience and practice that constitute a portion of GVIC’s intellectual property and proprietary knowledge. All research material is proprietary and not available to the public or offered for sale to any other entity. Fundamental analysis is generally understood to concentrate on factors that determine a company’s current value and projected future value, based on financial estimates. This method of analysis normally encourages equity and debt investments in companies that are undervalued or priced below their perceived value. Uncertainty arises in this analytical methodology when the public market value of a security does not align with GVIC’s assessment of the value of that security. GVIC’s investment strategies necessarily entail uncertainties that are inherent when investing in an uncertain world. GVIC invests in and trades securities and other financial instruments for clients using strategies and investment techniques that are subject to various uncertainties, including some amount of company leverage and the potential illiquidity of a company’s security. GVIC clients must be prepared to bear the possibility of capital losses and extended periods of market price variability. GVIC applies this method of analysis by focusing on the following investment strategies: Short-Term and Long-Term Strategies – Long-term investment strategies involve holding securities for a period of at least one year. Short-term investment strategies involve holding securities for a period of less than one year. When implementing long-term investment strategies, GVIC believes that the price of a security will be higher in the future than at the time of purchase, and that price appreciation will occur over a period of more than one year. The appreciation of a single security over this period, and the longterm growth of broad financial markets, cannot be assured. Securities purchased in client accounts may decline in value over time, even if broad financial markets increase in value over the same period. In addition, purchasing securities with the intent to hold such securities for more than one year may involve an opportunity cost, or the loss of potential gain from an alternative investment.

Activist Strategies – GVIC may, in certain circumstances, pursue “activist” strategies, which require (a) us to properly identify companies whose security price can be increased through our active influence on, and involvement in, the management of such companies or through other strategies to influence or control corporate decision-making; (b) our clients to acquire sufficient securities or other instruments of or relating to such companies, such that GVIC’s beneficial ownership of such securities is sufficient to exercise influence or control; (c) our avoidance of triggering anti-takeover and regulatory obstacles while aggregating our position; (d) management of such companies and other stakeholders responding positively to the our proposals; and (e) the market price of such companies’ securities increasing in response to actions taken by such companies in connection with our proposals. There can be no assurance that any of the foregoing will succeed. Successful execution of an investment strategy with respect to a company can depend on the actions of other stakeholders, whose interests may not be aligned with those of our clients. Moreover, securities that we believe are fundamentally undervalued or incorrectly valued may not ultimately be valued in the capital markets at prices and/or within the timeframe we anticipate, even if our strategy is successfully implemented. Even if the price for a company’s security has increased, there is no assurance that the client will be able to realize any increase in the value of the investment. The following risks can be associated with GVIC’s methods of analysis and strategies: Investments in Undervalued Securities – GVIC’s investment strategies are designed to invest in securities it believes are undervalued. The identification of investment opportunities in undervalued securities requires skill and experience, and there can be no assurances that such opportunities will be identified, or when identified, will result in successful investment outcomes. While investments in undervalued securities offer the potential opportunity for significant capital appreciation, these investments involve an element of financial uncertainty and can result in capital loss. In GVIC’s active investment strategy, this uncertainty can be amplified by concentration (discussed below). GVIC can invest a client’s assets in fixed income securities, including, without limitation, commercial paper and debt securities. A major economic recession could severely disrupt the market for such securities and could have an adverse impact on the value of such securities. In addition, it is likely that any such economic downturn could adversely affect the ability of the issuers of such securities to make payments thereon, increasing the incidence of default for such securities. Unforeseen circumstances such as market disruptions could cause the price of such securities to decline substantially. Investing in securities that appear to be undervalued is no guarantee that these securities will not be trading at even more undervalued levels at a time such securities are sold. Concentration of Holdings – At any given time, a client’s assets can become concentrated in the holdings of a single company or small group of companies. In such cases, a client’s portfolio will be more susceptible to fluctuations in value resulting from conditions affecting such company or group of companies compared to the results of a more broadly diversified portfolio. As a result, a client’s returns could be more volatile and could be affected substantially by the success or failure of only one or a few holdings. GVIC does not generally hedge client positions to protect against such fluctuations. Trading in Illiquid Securities – Certain securities in which GVIC invests client assets can be relatively illiquid. Such securities could prevent a client from liquidating positions in a prompt and orderly manner and subject the client to loss. Highly Variable Market Pricing – The prices of a client’s investment holdings can be highly variable. Price movements of some investments in which GVIC’s clients can be invested are influenced by a variety of

factors including, among other things, interest rates, levels of supply and demand, actual or perceived credit risks, regulatory changes, and national and international political and economic events and policies. In addition, governments can from time to time intervene in certain investment markets, particularly those in government bonds, currencies, and financial instruments, which can adversely affect return on investment. GVIC’s clients are also subject to the uncertainty of the failure of any exchange on which securities trade. Non-U.S. Investments – GVIC can invest a portion of a client’s portfolio outside the U.S. in non-dollar denominated securities, including in securities issued by foreign companies and the governments of foreign countries and in foreign currencies. These investments involve different types of uncertainties than those typically associated with investments in U.S. companies or securities issued by the U.S. government. Because investments issued by foreign issuers can involve foreign currencies, clients can be affected positively or negatively by changes in currency exchange rates (including as a result of the devaluation of a foreign currency) and in exchange control regulations and can incur transaction costs in connection with conversions between currencies. In addition, unlike with most U.S. companies, GVIC may not be able to obtain the same amount of information regarding a foreign company, or such information may not be reliable. The regulation of securities markets in some foreign countries can be less rigorous than that of those in the U.S. Some foreign securities markets have a higher potential for price variability and illiquidity compared to most U.S. securities markets. With respect to certain countries, there can be the possibility of expropriation or confiscatory taxation, political, economic, or social instability, limitation on the removal of funds or other assets or the repatriation of profits, restrictions on investment opportunities, the imposition of trading controls, withholding or other taxes on interest, dividends, capital gain, other income, gross sale, or disposition proceeds, import duties or other protectionist measures, various laws enacted for the protection of creditors, greater uncertainty of nationalization, or diplomatic developments that could adversely affect investments in those countries. Currency – GVIC can invest in equity and debt securities denominated in various currencies, the price of which is determined with reference to such currencies. To the extent unhedged, the value of the net asset will fluctuate with the U.S. dollar exchange rate as well as with price changes in the various local markets and currencies. Thus, any change in the value of the U.S. dollar relative to the currencies in which an investment is denominated can magnify the effect of increases or decreases in the prices of the client’s securities in their local markets. Currency forward contracts and over-the-counter options can be utilized to hedge against any potential currency fluctuations. GVIC is not required to hedge and typically does not use derivatives to hedge. There can be no assurance that any hedging transactions, even if undertaken, will be effective. Credit Risk – Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer’s securities held by a client. Regulatory Restrictions – The investment strategies pursued by GVIC can be affected by state law, U.S. federal law, and the laws of other applicable jurisdictions governing the securities in which clients invest, which can inhibit GVIC’s ability to freely acquire and dispose of certain securities. Such regulations can materially adversely affect the value of a client’s investment. Any changes to government regulations can make some or all forms of investment strategies unlawful or impractical. Accordingly, such changes, if any, could have an adverse effect on the achievement of a client’s investment objective. Minority Investments; Third-Party Stakeholders – GVIC will primarily invest in minority positions (generally less than 20 percent of the common stock outstanding) of companies and GVIC’s clients will generally have no legal right to appoint a director or otherwise exert material influence or control over the management of such companies. As a result, the value of a client’s investment will be based, in large

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GVIC is a federally registered investment adviser; therefore, we are not required to respond to this item. to respond to this item.

Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. We do not have any required disclosures under this item. Other Financial Industry Activities and Affiliations Other Financial Industry Activities and Affiliations Arrangements with Affiliated Entities We serve as the investment manager to GVP 2021-A, L.P., a private investment fund in which you may be solicited to invest. We are affiliated through common control and ownership with GVP 2021-A L.L.C., the general partner of GVP 2021-A, L.P. GVP 2021-A, L.P. is offered to sophisticated investors, who meet certain requirements under applicable state and/or federal securities laws. Investors to whom GVP 2021A, L.P. is offered will receive the fund’s Governing Documents, as applicable. The fees charged by GVP 2021-A, L.P. are separate and distinct from our advisory fees. You should refer to the Governing Documents of GVP 2021-A, L.P. for a complete description of the fees, investment objectives, risks, and other relevant information associated with investing in GVP 2021-A, L.P. Persons affiliated with our firm may have made an investment in GVP 2021-A, L.P. and may have an incentive to recommend GVP 2021-A, L.P. over other investments. GVP 2021-A, L.P. currently holds one security, Rocky Mountain Chocolate Factory, Inc. (“RMCF”), listed on the Nasdaq Capital Market under the ticker RMCF. As indicated in the subscription documents signed by fund investors, clients are not charged a management fee; however, pursuant to side letters entered into with each fund investor, carried interest will be charged at the conclusion of the fund based on the fund’s performance. In addition, the General Partner, not GVP 2021-A, L.P., will bear all ordinary operating expenses. It is possible that investors in the fund could invest in RMCF and pay less than an investment in RMCF through GVP 2021-A, L.P. Jeffrey R. Geygan, Executive Chairman, Chairman of the Board of Directors, and the controlling shareholder of GVIC, is also a Director of RMCF, a role for which he receives compensation from RMCF. This creates a conflict of interest because Jeffrey R. Geygan has an incentive to recommend investment in GVP 2021-A, L.P. To mitigate this conflict, and in accordance with GVIC’s Code of Ethics, once he was appointed to the Board of Directors of RMCF, Jeffrey R. Geygan was recused from any investment decisions made by GVIC relating to RMCF. On November 26, 2024, GVIC entered into a letter agreement (the “Letter Agreement”) with RMCF and certain other parties signatory thereto, pursuant to which GVIC was granted certain governance rights, including the right to appoint a director, and mutually agree with RMCF upon the appointment of another director, to RMCF’s Board. As a result of the foregoing, GVIC may be construed to exercise limited control

over RMCF, and the outcome of GVIC’s investment in RMCF may be partially dependent on GVIC’s decisions with respect to RMCF. On December 17, 2025, GVIC entered into an amendment to the Letter Agreement amending GVIC’s maximum ownership in the common stock of RMCF from 29.9% to 25.0% of the outstanding common stock. On August 28, 2025, RMCF2 Credit, LLC, a special purpose investment entity affiliated with Jeffrey R. Geygan, entered into a credit agreement with RMCF pursuant to which RMCF received an advance in the principal amount of $1.2 million. An investment in RMCF through an advisory account with GVIC is more liquid than a partnership interest in GVP 2021-A, L.P. (that is, the securities are more accessible and subject to fewer restrictions), which can only be redeemed with permission from the General Partner. Referral arrangements with an affiliated entity present a conflict of interest for us because we may have a direct or indirect financial incentive to recommend an affiliated firm’s services. You are under no obligation to use the services of any firm we recommend or invest in any Fund we recommend, whether affiliated or otherwise, and may obtain comparable services, investments, and/or lower costs elsewhere. We have a wholly owned subsidiary, Global Value Research Company India Private Limited, with an office in Hyderabad, India, which assists with our research and analysis. All research prepared by us or Global Value Research Company India Private Limited is based on public information, is for informational purposes only, and is not intended as an offer to sell or a solicitation to buy securities. We do not engage in, or receive compensation from, any investment banking or corporate finance-related activities with the companies discussed in its reports. Our research is used for internal purposes only. Associated Persons Serving as Directors of Public Companies Our principals or employees, from time to time, serve on the boards of directors of companies in which client funds are invested. Because these principals or employees are associated with us, and may have influence over other principals or employees of us, a conflict of interest exists when we direct client funds to purchase shares of any such company based on our recommendation. To mitigate this conflict, and in accordance with GVIC’s Code of Ethics, when our principals or employees serve on the board of directors of a company in which client funds are invested, these individuals are recused from any investment decisions relating to that company’s securities. GVIC’s Chief Compliance Officer maintains records of investment meetings held by GVIC regarding such companies that document such recusals. On August 12, 2021, Jeffrey R. Geygan was appointed to the Board of Directors of Rocky Mountain Chocolate Factory, Inc. (“RMCF”), listed on the Nasdaq Capital Market under the ticker RMCF, a position for which he receives compensation. We are affiliated through common control and ownership with GVP 2021-A L.L.C., the general partner of GVP 2021-A, L.P., and serve as the investment adviser to GVP 2021-A, L.P., a private fund that invests solely in RMCF. On January 17, 2025, James P. Geygan was appointed to the Board of Directors of Fluent, Inc. (“FLNT”), listed on The NASDAQ Stock Market, LLC under the ticker FLNT, a position for which he receives compensation. On June 22, 2026, Jeffrey R. Geygan was appointed to the Board of Directors of Loop Industries, Inc. (“LOOP”), listed on The NASDAQ Stock Market, LLC under the ticker LOOP, a position for which he receives compensation. On September 8, 2026, Jeffrey R. Geygan was appointed as the Chairman of the Board of Directors of LOOP.

A separate portfolio manager in GVIC supervises the investment research and analysis RMCF, and makes all investment decisions relating to RMCF, including if and when to purchase or sell securities of RMCF, for client accounts, without discussions with Jeffrey R. Geygan. All such decisions are made based upon the investment objective and risk tolerance of each client's account, and in the best interest of each client. Furthermore, we have internal procedures that restrict our employees or associated individuals from purchasing or selling the securities of RMCF for their own account, or accounts in which they have a beneficial interest, based on material non-public information they may receive as a result of Jeffrey R. Geygan’s relationship with RMCF. Separate research analysts in GVIC supervise the investment research and analysis of FLNT, and make all investment decisions relating to FLNT, including if and when to purchase or sell securities of FLNT, for client accounts, without discussions with James P. Geygan. All such decisions are made based upon the investment objective and risk tolerance of each client's account, and in the best interests of each client. Furthermore, we have internal procedures that restrict our employees or associated individuals from purchasing or selling the securities of FLNT for their own account, or accounts in which they have a beneficial interest, based on material non-public information they may receive as a result of James P. Geygan’s relationship with FLNT. A separate portfolio manager in GVIC supervises the investment research and analysis LOOP, and makes all investment decisions relating to LOOP, including if and when to purchase or sell securities of LOOP, for client accounts, without discussions with Jeffrey R. Geygan. All such decisions are made based upon the investment objective and risk tolerance of each client's account, and in the best interest of each client. Furthermore, we have internal procedures that restrict our employees or associated individuals from purchasing or selling the securities of LOOP for their own account, or accounts in which they have a beneficial interest, based on material non-public information they may receive as a result of Jeffrey R. Geygan’s relationship with LOOP. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Description of Our Code of Ethics We comply with applicable laws and regulations governing our practices. Our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to always protect your interests and to demonstrate our commitment to our fiduciary duties of loyalty and care. All persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm are also required to promptly report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of sensitive or confidential information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions We are affiliated through common control and ownership with GVP 2021-A L.L.C., the general partner of GVP 2021-A, L.P., a private investment fund in which you may be solicited to invest. Our firm, certain members of its management, and other knowledgeable employees may acquire, directly or indirectly, investment interests in GVP 2021-A, L.P. or have other financial interests in GVP 2021-A, L.P. This presents a conflict of interest because we have investments in and/or are compensated by GVP 2021-A, L.P. Conflicts that arise are mitigated through our fiduciary obligation to act in the best interest of our clients, contractual limitations that govern our activities as investment manager or general partner, as applicable, and the requirement of us not to place our interests before our clients’ interests when managing GVP

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