Mork Capital Management, LLC

Mork Capital Management, LLC (“Mork Capital” or the “Firm”), commenced operations in 2002, and is a limited liability company and an SEC registered investment adviser. Mork Capital is 100% owned by Michael Paul Mork. The Firm serves as the investment manager and General Partner to its affiliated private investment fund, MCAPM, L.P. (the “Fund”). Mork Capital does not offer advisory services to any other types of clients. The Fund is claiming an exemption from SEC registration under Rule 3(c)1 of the Investment Company Act and is available for investment only to a limited number of sophisticated investors who meet the definition of “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), or are otherwise exempt. The Fund’s principal investment objective is to generate long-term capital appreciation through a strategy of diversification, employing several different investment styles to be determined by the General Partner from time to time. In managing the Fund, Mork Capital identifies and evaluates investment opportunities, constructs and manages the Fund’s portfolio, and monitors investments on an ongoing basis. The specific investment objectives, strategies, and restrictions of the Fund are outlined in the Fund’s confidential private offering memorandum, limited partnership agreement, and subscription agreement (collectively, referred to herein as the “Offering Documents”). Please also refer to Item 8 for additional information about the Fund’s investment strategies. Prospective investors are provided with copies of the Offering Documents, and it is important that each prospective investor fully read the materials in detail prior to investing for a complete understanding of the objectives, risks, conflicts, and fees involved when investing in the Fund. As of December 31, 2025, Mork managed $ 157,414,192 in Fund assets on a discretionary basis.

As compensation for its services as General Partner and investment manager to the Fund, Mork Capital receives an annual advisory fee (the “Advisory Fee”). The Advisory Fee is paid quarterly in advance at the beginning of each fiscal quarter of the Partnership and is calculated based on each investor’s Capital Account balance at the end of the immediately preceding fiscal quarter. The Fund currently offers the following two interests: “MCAPM, L.P. Interest” and “NXT Energy Sub-Account Interest”. The annual Advisory Fee schedule is a tiered schedule based on an investor’s Capital Account balance, as follows:

MCAPM, L.P. Interest Capital Account Balance First $10,000,000 $10,000,001 – $20,000,000 $20,000,001 – $30,000,000 Over $30,000,000

Annual Fee Rate 1.00% 0.50% 0.25% 0.125%

NXT Energy Sub-Account Interest Capital Account Balance First $10,000,000 $10,000,001 – $20,000,000 $20,000,001 – $30,000,000 Over $30,000,000

Annual Fee Rate 0.50% 0.25% 0.125% 0.0625%

Where an investor holds both MCAPM, L.P. Interests and NXT Energy Sub-Account Interests, fee tiers are applied sequentially in accordance with the Fund’s offering documents. The Advisory Fee is payable in advance. If an investor’s interest is terminated prior to the end of a billing period, fees will be prorated, and any unearned portion will be refunded. Other Expenses In addition to the Advisory Fee, the Fund pays its own operating and other expenses as set forth in the Fund’s Offering Documents. The General Partner is responsible for paying its own overhead and personnel expenses, including compensation, employee benefits, and office rent. The Fund is responsible for a broad range of expenses incurred in connection with its investment program and operations, including but not limited to: investment-related and trading expenses (such as brokerage commissions, settlement and clearing costs, financing costs, and research-related expenses); professional fees (including legal, accounting, audit, and tax services); regulatory and compliance costs (including regulatory filings and ongoing compliance obligations); insurance premiums; administrative and custodial expenses; valuation-related expenses; and other ordinary operating expenses of the Fund. The Fund also bears expenses associated with offering and maintaining investor interests, including communication with investors and regulatory or compliance-related matters. Certain organizational and extraordinary expenses may also be borne by the Fund as permitted under the Offering Documents. Expenses are generally allocated among investors on a pro rata basis; however, certain expenses incurred for the benefit of specific investors may be allocated solely to those investors. To the extent the General Partner pays expenses on behalf of the Fund, the Fund will reimburse the General Partner for such amounts in accordance with the Fund’s Offering Documents. Certain research-related expenses can be paid using soft dollar arrangements where

permitted by law. For detailed information regarding fees, expenses, and conflicts of interest pertaining to the Fund, investors should read the Fund’s Offering Documents.

In general, the Fund intends to make direct and indirect investments which the General Partner considers as having potential for capital growth in numerous U.S. and foreign publicly traded small, medium and large-sized companies, ADRs of foreign companies traded on a U.S. national or regional stock exchange or the NASDAQ, and in ETFs traded on U.S. or possibly on certain foreign exchanges. There is no assurance that the Fund’s investment objectives will be achieved. The Fund has the ability to invest in common and preferred stocks, convertible securities, options, warrants, derivatives, other equity or equity-related securities, bonds, notes, and/ or other fixed income instruments. In addition, the Fund may purchase puts and calls on stocks and stock indexes and sell covered put and call options on stock. Also, the Fund will use margin debt in its investment program, take short positions in securities and engage in hedging transactions and certain types of swaps. All of these investments and transactions are subject to inherent market risks and fluctuations in value due to earnings, economic conditions and other factors. Potential investors should be aware that investing in securities involves a significant degree of risk. There can be no assurance that Mork Capital will achieve the investment objectives of the Fund and a loss of the principal amount invested is possible.

Risks of Investments Below is a list of material risks that are applicable to the Fund and its underlining investments. Each existing and prospective investor should be aware of certain risk factors, which include, but are not limited to, the below. The performance of Mork Capital’s prior investments is not indicative of future results. While the Firm intends to make investments that have estimated returns commensurate with the risks undertaken, there can be no assurances and loss of principal investment is possible. 1. Business Risks. The Fund invests in securities, which may involve varying degrees of risk, and operating results in a specified period will be difficult to predict. Such investments involve a high degree of business and financial risk that can result in substantial losses. 2. Concentration of Investments. The Fund may, at times, hold concentrated positions in certain issuers, sectors or investment styles. As a result, the Fund’s investment portfolio could become highly concentrated, and the performance of a few holdings or of a particular industry may substantially affect the Fund’s performance return. 3. Illiquidity. An investment in the Fund should be considered illiquid. 4. Leveraged Investments. Leverage generally magnifies both the Fund’s opportunities for gain and its risk of loss from a particular investment. The cost and availability of leverage is highly dependent on the state of the broader credit markets, which is difficult to accurately forecast, and at times it may be difficult to obtain or maintain the desired degree of leverage. 5. Limited Transferability of Fund’s Partnership Interests. There will be no public market for the Fund’s partnership interests, and none is expected to develop. There are substantial restrictions upon the transferability of partnership interests under the Limited Partnership Agreement and applicable securities laws. 6. Reliance on the General Partner. Control over the operation of the Fund is vested with the General Partner, and the Fund’s future profitability depends largely upon Mork Capital’s business and investment acumen. The loss or reduction of service of one or more of the Mork Capital’s principals could have an adverse effect on the the Firm’s ability to realize the Fund’s investment objectives. Limited partners generally have no right or power to take part in the management of a Fund, and as a result, the investment performance of the Fund will depend on the actions of the General Partner. In addition, certain changes in the General Partner or circumstances relating to the General Partner may have an adverse effect on the Fund. 7. Conflicting Investor Interests. Limited Partners may have conflicting investment, tax, and other interests with respect to their investments in the Fund, including conflicts relating to the structuring of investment acquisitions and dispositions. Conflicts may arise in connection with decisions made by the General Partner regarding an investment that may be more beneficial to one Limited Partner than another, especially with respect to tax matters. In structuring, acquiring and disposing of

investments, the General Partner generally will consider the investment and tax objectives of the Fund and its limited partners as a whole, not the investment, tax, or other objectives of any limited partner individually. 8. Non-U.S. Investments. The Fund invests in non-U.S securities and such investments can be subject to certain additional risk due to, among other things, potentially unsettled points of applicable governing law, the risks associated with fluctuating currency exchange rates, the application of complex U.S. and non-U.S. tax rules to cross-border investments, and possible non-U.S. tax return filing requirements for the Fund and/or the Partners. Additional risks of non-U.S. investments include: (a) economic dislocations in the host country; (b) less publicly available information; (c) less well-developed regulatory institutions; (d) greater difficulty of enforcing legal rights in a non-U.S. jurisdiction; (e) civil disturbances; (f) government instability; and (g) nationalization and expropriation of private assets. Moreover, non-U.S. companies may not be subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable to those that apply to U.S. companies. 9. Uncertain Economic and Political Environment. The current global economic and

political climate is one of uncertainty. Prior acts of terrorism in the United States, the threat of additional terrorist strikes, and the fear of a prolonged global conflict have exacerbated volatility in the financial markets and can cause consumer, corporate and financial confidence to weaken, increasing the risk of a “self-reinforcing” economic downturn. The availability of credit for consumers, homeowners and businesses, including credit used to acquire businesses, continues to be somewhat restricted. This may have an adverse effect on the economy generally and on the ability of the Fund to execute its investment strategy.

10. Market Conditions. Any material changes in the economic environment, including a slow-down in economic growth and/or changes in interest rates or foreign exchange rates, could have a negative impact on the performance of securities. The Fund’s performance can be affected by deterioration in public markets and by market events. Movements in foreign exchange rates may adversely affect the value of investments and the Fund’s performance. The value of publicly traded securities may be volatile and difficult to sell as a block, even following a realization through listing. The impact of market and other economic events may also affect a Fund’s ability to raise funding to support its investment objective and also the level of profitability achieved on realizations of investments. 11. Margin Risk: which is the risk that the use of borrowed capital, such as margin, to increase the potential return of an investment can increase the risk of an investment and can magnify the effect of any losses. The use of leverage is a speculative technique. Using borrowed money (whether through trading on margin or any other method of borrowing) to finance the purchase of securities involves interest charges and entails greater risk than using cash resources only.

As outlined in Item 4 above, Mork Capital only provides investment advice to its affiliated private investment fund, MCAPM, L.P. The Firm does not offer advisory services to any other types of clients. The limited partners in the Fund can include individuals, banks or thrift institutions, other investment entities, pension and profit-sharing plans, trusts, estates or charitable organizations or other corporations or business entities and may include, directly or indirectly, principals or other employees of Mork Capital. The Fund has a minimum investment amount, which is outlined in the Fund’s Offering Documents. Such minimum investment amounts vary, are outlined in the Fund’s Offering Document and may be waived by Mork Capital.

Mork Capital does not charge the Fund a performance-based fee. "Side-by-Side Management" refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time manages other accounts for which fees are assessed on a performance fee basis. Because Mork Capital has no performance-based fee accounts, it has no side-by-side management.

The Fund is organized as a limited partnership and the General Partner is Mork Capital. The Firm does not have any ownership affiliations, and neither it nor any of its supervised persons are registered or has an application pending to register as a broker-dealer or registered representative of a broker-dealer, or a futures commission merchant, commodity pool operator, or commodity trading advisor, or associated person of such entities. Mr. Peter Mork, who oversees the Firm’s operations, also serves on the Board of Directors of NXT Energy Solutions, Inc. (“NXT”), which is a publicly traded company that the Fund has invested in. Peter Mork does not participate in day-to-day management or operational decision-making at NXT. In connection with his role, he receives standard annual compensation for his time and service on the Board in the same manner and amount as other Board members. This outside business activity, along with the associated conflicts are disclosed in detail in the Fund’s Offering Documents, which should be read fully prior to investing in the Fund. Please also refer to Item 11 below for more information.

A. Description of Code of Ethics The Investment Advisers Act of 1940 (“The Act”) imposes a fiduciary duty on investment advisers. As a fiduciary, Mork Capital and its principals and employees (“Supervised Persons”) have a duty of utmost good faith and integrity to act solely in the best interests of the Firm’s clients. To that end, Mork Capital has adopted a Code of Ethics and Securities Trading Policy and Procedures (the “Code”), which sets forth principles and standards of conduct that are expected of Mork Capital’s Supervised Persons. The Code consists of the following core principles and applies to all the Firm’s Supervised Persons: 1. The interests of clients will be placed ahead of the Firm’s or any Supervised Person’s own investment interests. 2. Supervised Persons are expected to conduct their personal securities transactions in accordance with the Firm’s Code requirements and will strive to avoid any actual or perceived conflict of interest with the Fund. 3. Supervised Persons will not take inappropriate advantage of their position within the Firm. 4. Supervised Persons are expected to act in the best interest of the Fund. 5. Supervised Persons are expected to comply with federal securities laws. Strict adherence to these policies and other policies and procedures of the Firm will assist each Supervised Person in complying with this important requirement.

The Code also addresses conflicts that arise from Supervised Persons’ personal trading. For example, the Code requires certain Mork Capital Supervised Persons to obtain pre-approval for certain personal securities transactions and report their personal securities transactions. In addition, Supervised Persons are not permitted, in any connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by the Fund: a) To defraud the Fund or the Fund’s investors in any manner; b) To mislead any investors, including by making a statement that omits material facts; c) To engage in any act, practice or course of conduct which operates or would operate as a fraud or deceit upon such client; d) To engage in any manipulative practice with respect to the Fund or its investors; or e) To engage in any manipulative practice with respect to securities, including price manipulation. A copy of the Code will be provided to any investor or prospective investor upon request by calling us at (707) 431-1057. Mork Capital Management and its Supervised Persons may come into possession, from time to time, of material, non-public or other confidential information about public companies which, if disclosed, might affect an investor’s decision to buy, sell, or hold a security. Under applicable law, Mork Capital and its Supervised Persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any person, regardless of whether such person is a client of Mork Capital. Accordingly, should Mork Capital or any of its Supervised Persons come into possession of material nonpublic or other confidential information with respect to any public company, Mork Capital is prohibited from acting upon and/or communicating such information to investors. B. Participation and Interest in Fund Transactions Mork Capital’s Supervised Persons have in the past and may in the future buy or sell securities for their own personal accounts that the Firm buys or sells for the Fund. Mork Capital understands that this could create a conflict of interest, where the Supervised Person’s interest is at odds with the interests of the Fund. To mitigate such conflict, Mork Capital has internal controls in place to help ensure that Supervised Persons comply with the Firm’s Code of Ethics requirements regarding personal trading. Discussed in further detail in the Fund’s Offering Documents and in Item 14 below, Mr. Peter Mork is currently on the Board of Directors of NXT Energy Solutions, Inc (“NXT”). The Fund holds a position in NXT which predates Peter Mork’s Board membership. Peter Mork and Michael Mork each also hold personal investments in NXT outside of the Fund, and both Peter Mork and Michael Mork hold a pro rata interest in NXT through their investments in the Fund. Peter Mork and Michael Mork’s investments in NXT outside of the Fund were made on the same terms as the other investors, including the Fund, at the time such investments were made. Peter Mork and Michael Mork did not receive any preferential treatment or side agreements in connection with their personal investments in NXT. All such investments occurred either prior to or independent of Peter Mork’s appointment to the Board.

A. Selection Criteria The Fund has a prime brokerage arrangement with Jefferies LLC, wherein Jefferies provides brokerage, custody, and record-keeping services for the Fund. Under this arrangement, Mork Capital has discretion to place trades with other broker-dealers for execution, with all trades settling through Jefferies as prime broker and custodian. B. Best Execution When trading, Mork Capital selects a broker-dealer for execution that the Firm believes can provide the best overall deal at the time of the trade (“best execution”). While Mork Capital strives to achieve the best execution possible for the Fund’s securities transactions, this does not require the Firm to solicit competitive bids and the Firm does not have an obligation to seek the lowest available commission cost. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the overall best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including among other things, the value of any research provided, their execution capability, commission rates, and responsiveness. As part of our best execution obligation, Mork Capital evaluates its trading process and the brokers utilized. The evaluation will usually include, but not limited to execution prices, commissions/transaction costs, research offered, the brokers’ reliable and accurate communications and settlement processing, and use of automation. C. Soft Dollars Although the Mork Capital’s allocation of brokerage business is based on a desire to get the best execution possible, it selects brokers in part on the basis of products, research and services. Mork Capital’s general policy is to comply with the provisions of Section 28(e) of the Exchange Act (“Section 28(e)”) when entering into any soft dollar arrangements. Section 28(e) generally allows investment advisers to use client commissions to pay for certain brokerage and research services under certain circumstances without breaching their fiduciary duties to clients. Therefore, in circumstances in which the Firm feels that execution is comparable, we have in the past and may in the future place certain trades with a broker-dealer that is providing brokerage and research services to us (“Research Broker”). Brokerage and research services provided by Research Brokers can include, among other things, effecting securities transactions, performing services incidental thereto (such as clearance, settlement and custody), and/or providing information regarding the economy, industries, sectors of securities, individual companies, statistical information, taxation; political developments, legal developments, technical market action, pricing and appraisal services, credit analyses; risk measurement analysis and performance analysis.

Such research services can be received in the form of written reports, telephone conversations, personal meetings with security analysts and/or individual company management and attending conferences. The research services provided by a Research Broker can be proprietary to the broker-dealer and/or provided by a third party (i.e., originates from a party independent from the broker -dealer providing the execution services). In selecting a Research Broker, Mork Capital will make a good faith determination that the amount of the commission charged is reasonable in relation to the value of the brokerage and research services received, viewed in terms of the specific transactions. Subject to Section 28(e), the Firm can pay a Research Broker a brokerage commission in excess of that which another broker might have charged for effecting the same transaction, in recognition of the value of the brokerage and/or research services provided by the broker. This practice is commonly referred to as “soft dollars”. Mork Capital believes it is imperative to our investment decision-making process to have access to this type of research and brokerage. The receipt of brokerage and research services from any broker executing transactions for the Fund will not result in a reduction of our customary and normal research activities, and the value of such information is, in our view, indeterminable. Nevertheless, the receipt of such research can be deemed to be the receipt of an economic benefit by the Firm, and although customary, is deemed to create a conflict of interest between Mork Capital and the Fund. Therefore, the Firm feels it is important for investors to be aware of the issues surrounding soft dollars. In cases when Mork Capital receives both non-research (e.g., administrative or accounting services etc.) and research benefits from the services provided by the Research Brokers, the Firm will make a good faith allocation between the non-research and research portion of the services received, and will pay “hard dollars” (i.e., Mork Capital will pay from their own monies) for the non-research portion. In making a good faith allocation between research services and nonresearch services, a conflict of interest exists because of the allocation of the costs of such services and benefits between those that primarily benefit Mork Capital and those that primarily benefit the Fund. We will always put the Fund’s interests first.

A. Compensation for Referrals Currently, Mork Capital does not have any arrangement with, and does not pay, any affiliated or unaffiliated promoters or finders to refer potential new investors for the Fund.

B. Other Compensation Peter Mork is currently on the Board of Directors (“Board”) of NXT Energy Solutions, Inc. (“NXT”), having been appointed to that role as of July 15, 2024. Peter Mork does not participate in day-to-day management or operational decision-making at NXT. In connection with his role, he receives standard annual compensation for his time and service on the Board in the same manner and amount as other Board members. The Fund holds a position in NXT which pre-dates Peter Mork’s Board membership. Please also refer to information in Item 11 above.

Registered investment advisers are required to disclose all material facts regarding any legal

or disciplinary events that would be material to an investor’s evaluation of the Firm or the integrity of its management. Mork Capital and its management persons have not been subject to any material legal or disciplinary events required to be discussed in this Brochure.

Mork Capital performs ongoing reviews of the Fund’s transactions and securities holdings, The reviews are based upon and can be triggered by a variety of factors, which include but are not limited to the economic environment, outlook for the securities markets and the merits of the securities in which the accounts are invested. Each limited parter in the Fund receives quarterly and annual statements outlining their Capital Account. In addition, the Fund’s financials are audited annually and each limited partner receives a copy of the audited report within 120 days of the Fund’s fiscal year end.

Pursuant to Rule 206(4)-2 of the Investment Advisers Act of 1940, Mork Capital is deemed to have custody of the Fund’s assets since it serves as the General Partner to the Fund. In accordance with the requirements of 206(4)-2, the Fund receives annual audits of their financial statements, which is performed by an independent public accountant that is registered with, and subject to examination the Public Company Accounting Oversight Board (PCAOB). Copies of the annual audited financial statements are distributed to the Fund’s investors within 120 days of the Fund’s fiscal year end.

Mork Capital generally has discretionary authority to make all investment decisions on behalf of the Fund. The Fund’s Offering Documents generally impose certain limitations on the Firm’s investment discretion, which limitations can only be waived by the Fund’s limited partners. Mork Capital assumes this discretionary authority pursuant to the terms of the Offering Documents. Please note investment advice is provided directly to the Fund and not individually to the Fund’s investors.

Mork Capital votes proxies on securities held in the Fund’s portfolio and has adopted policies and procedures in an effort to ensure that all votes are cast in the best interests of the Fund and that the proper documentation is maintained relating to how the proxies were voted. These policies and procedures are summarized as follows: Mork Capital has adopted pre-determined proxy voting guidelines (the “Guidelines”) to make every effort to ensure the manner in which shares are voted is in the best interest of the Fund and the value of the investment. In addition, the policy allows the Firm to vote a proxy contrary to the Guidelines if Mork Capital determines that such action is in the best interests of the Fund. If at any time, Mork Capital becomes aware of any type of potential or actual conflict of interest relating to a proxy proposal, such potential or actual conflict will be promptly reported to the Chief Compliance Officer. Conflicts will be handled in a number of ways depending on the type and materiality. The method selected by us will depend upon the facts and circumstances of each situation and the requirements of applicable laws and will always be handled in the Fund’s best interest.

A complete copy of our current Proxy Voting Policies & Procedures is available upon request. Investors can obtain information on how the Fund’s proxies were voted by contacting Mork Capital at the principal office indicated on the cover page of this Brochure.

Mork Capital Management does not require prepayment of more than $1,200 in management fees, six months or more in advance of the services, nor does it have any other events requiring disclosure under this item of the Brochure. Mork Capital does not have any financial commitments that impair its ability to meet contractual and fiduciary obligations to the Fund and has not been the subject of a bankruptcy proceeding.