Alexander Capital Advisors, LLC: investment adviser

Any such consultation services, to the extent rendered, will be rendered exclusively on an unsolicited basis, for which we shall not receive any separate or additional fee. ACA also serves as the general partner of a private fund, The Plato Fund L.P. (the “Fund”), and provides investment advice to the Fund. The Fund is a hedged long‐only value fund that seeks investment opportunities in U.S. listed companies predominately found in the Russell 2000 Index. The investment strategy of the Fund differs from the strategy we typically apply for other Client accounts and may be a suitable investment for a portion of a Client’s account. ACA offers advice to its Clients on the advisability of investing in the Fund but does not cause a Client’s assets to be invested in the Fund except at the direction of the Client. Interests in the Fund are privately offered only to “qualified clients” as defined below in Item 6 – Performance Based Fees and Side‐By‐Side Management. The Fund relies on an exemption from registration under the Investment Company Act of 1940. Investment in the Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the Fund, including the management fee and incentive fee, suitability, investment strategy, risk factors, and potential conflicts of interest, are set forth in the Private Offering Memorandum, Limited Partnership Agreement, and Subscription Agreement, which each subscriber is required to execute prior to being accepted as a limited partner of the Fund. Since ACA has a financial interest in the Fund, an investment in the Fund presents a conflict of interest for the Firm. C. Other than with respect to its investment advice to the Fund, ACA provides continuous advice to each Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client’s circumstances are established, we develop an understanding of each Client’s risk tolerance and create and manage a portfolio based on such. We will manage advisory accounts on a discretionary basis only. Account supervision is guided by the stated objectives of the Client (i.e., conservative total return, moderate total return, or aggressive total return). ACA will create a portfolio consisting of one or all the following: individual equities, ETFs, bonds, other investment products, and no‐load or load‐waived mutual funds. ACA will allocate the Client’s assets among various investments taking into consideration the financial objectives of the Client. The mutual funds will be selected based on any or all the following criteria: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s management style and philosophy; and the fund’s management fee structure.

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Portfolio weighting between funds and market sectors will be determined by each Client’s individual needs and circumstances as well as market conditions. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the Client’s behalf. Clients will retain individual ownership of all securities. When appropriate to the needs of the Client, ACA may recommend the use of short-term trading (securities sold within thirty (30) days), short sales, margin transactions or option writing. Because these investment strategies involve certain additional degrees of risk, they will only be recommended when consistent with the Client’s stated tolerance for risk. D. ACA is the sponsor and investment manager of the ACA Wrap‐Fee Program (hereinafter the “Program”). A “wrap‐fee” program provides the Client with advisory and brokerage execution services for one all‐inclusive fee. Except as described below, a Client participating in the Program is not charged separate fees for the respective components of the total service. To participate in the Program, all our Clients must direct the use of Schwab Advisor Services™ (formerly TD Ameritrade Institutional) Schwab Advisor Services to act as broker and custodian for their securities transactions. Participants in the Program are directed to the ACA Wrap‐Fee Brochure for additional information regarding the Program. E. ACA manages all Client accounts on a discretionary basis. As of January 31, 2026, the Firm had a total of $104,168,000 assets under management on a discretionary basis and no assets on a nondiscretionary basis.

The amount of the advisory fee will be based upon the value (market value or fair market value in the absence of market value) of the Client’s account on the month end prior to the payable date. Advisory fees are clearly shown as a separate line item on each Client’s monthly statement from the custodian. The fee charged is calculated as described above and is not charged based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds of a Client, except for those accounts described in Item 6 – Performance Based Fees and Side‐By‐Side Management. C. The fee includes all advisory and brokerage execution services. The fee does not include interest charges, electronic fund and wire transfer fees, American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law. The fee also does not include internal management fees and fund expenses charged by mutual funds and ETFs.

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D. A Client has the right to terminate its advisory agreement without penalty within five (5) business days after entering into the agreement. Furthermore, an advisory agreement may be canceled at any time, by either party, for any reason upon receipt of written notice. Since ACA’s fees must be paid in advance, upon termination of any account, any prepaid, unearned fees will be refunded within ninety (90) days, prorated as described below. The prorated refund is determined by verifying the date of termination and is based upon the number of months remaining in the current billing quarter. The fraction of prepaid quarterly fees to be refunded is calculated with the following formula: (1, 2, or 3) Number of months left in current quarter ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ (3) Number of months in quarter

X $ Fees Paid = $ Refund

E. ACA and its employees do not receive any compensation for the sale of securities or other investment products, including mutual funds.

We may entertain requests by certain “qualified clients” (as defined in Rule 205‐3(d) under the Investment Advisers Act of 1940, as amended) to enter into an advisory agreement that provides for compensation based on a share of the capital gains upon, or the capital appreciation of, the qualified client’s assets under management or account. This is referred to as a “performance fee.” As described below, this may present an incentive to favor one account over another, and thus a conflict of interest. At this time, ACA does not charge a performance fee to any Client other the Fund, as described below. ACA charges all Clients, other than as described in this section, a fee calculated as a percentage of assets under management. Clients who are invested in the Fund pay a management fee and an incentive fee, which is a performance‐based fee. Given that we manage both separately managed accounts and a pooled investment vehicle, the Firm has an incentive to favor the Fund (and performance‐based fee accounts); this conflict of interest is addressed in the Firm’s Policies and Procedures/Code of Ethics. Specifically, limitations are placed upon the timing of trades in the Fund relative to those in other Client accounts, and all trades are reviewed monthly to ensure adherence to these procedures.

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The Plato Fund Some of the Firm’s Clients have elected to invest in The Plato Fund, L.P., to which ACA acts as the general partner and provides investment advice. The Fund charges its limited partners a management fee and a performance‐based incentive fee. Performance fees are currently 20% of each partner’s net new profits, assessed annually on March 31, with a high watermark. For example: Year 1 – Partner A’s initial investment is $100,000 March 31 value: $120,000 Performance fee: $120,000 less $100,000 = $20,000 x 20% = $4,000 Year 2 March 31 value: $100,000 Performance fee: $0 ($120,000 is the high watermark) Year 3 March 31 value: $150,000 Performance fee: $150,000 less $120,000 = $30,000 x 20% = $6,000 Performance based fee arrangements may create an incentive for an advisor to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement.

The investment strategies used to implement any investment advice given to Clients include, but are not limited to, long term purchases (securities held at least a year), short term purchases (securities sold within a year), and when appropriate to the needs of the Client, we may recommend the use of short term trading (securities sold within thirty (30) days), margin transactions or option writing. Because these

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investment strategies involve certain additional degrees of risk, they will only be recommended when consistent with the Client’s stated tolerance for risk. Through our association with Schwab Advisor Services, Clients can and sometimes do receive institutional class mutual funds as part of their portfolio construction. Comprehensive research, disciplined value‐based strategy, absolute return focus and low portfolio volatility frame every investment decision at ACA. We search for well‐managed companies and securities that are temporarily priced below their true longer‐term value. Securities in our Clients’ portfolios share many of the following attributes:

Increasing cash flow and operating margins Attractive price to book value Increasing insider and management ownership Unique balance sheet characteristics Leadership changes among business lines within the company Known company board or management Business plans and strategies that consider equity and profitability

ACA concentrates on companies and securities with market capitalizations between $400 million and $4 billion. Investing in securities involves risk of loss that Clients should be prepared to bear. We generally aim to create well diversified portfolios for Clients, constructed to each Client’s individual risk tolerance. The investment strategies used on behalf of our Clients’ accounts may cover a wide range of investment types. Certain risks applicable to our management of our Clients’ assets are described below. Risks Associated with Securities Investments Generally. Investing in securities involves a variety of risks, including the loss of capital. The value of any such investments will depend upon many factors beyond our control. The securities markets generally are affected by, among other things, the state of the economy, inflation rates and unemployment, trade, fiscal and monetary policies and national and international political and economic events. All securities investments risk the loss of capital. The nature of the securities to be purchased and traded and the investment techniques and strategies we employ may increase this risk. Investing Generally. Our investment strategies are designed for investors seeking potential long‐term growth from investments, who do not require regular current income and who can accept a high degree of risk in their investments. In view of, among other things, our ability to invest in a wide range of securities and instruments on behalf of our Clients’ accounts and to use a broad variety of investment techniques, our investment management services may be deemed speculative in nature and are not intended to be a comprehensive investment program. No assurance can be given that our Clients will achieve their investment objectives or that our investment strategies will be successful. Institutional Risk. The institutions, including brokerage firms and banks, with which our Clients’ accounts trade or invest, may encounter financial difficulties that impair the operational capabilities or the capital position of such accounts. Institutions performing services for our Clients’ accounts may encounter financial difficulties that impair their operational capabilities. In such event, there is a risk that our Clients’ accounts could be faced with trading or settlement delays and/or portfolio losses.

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Non‐Diversification and Concentration. Diversifying an investment portfolio can reduce the risks of investing. This may include limiting the amount of money invested in any one company or, on a broader scale, limiting the amount invested in any one industry or geographic region. To retain flexibility, certain Client accounts may be non‐diversified. In addition, the size of a portfolio may limit our ability to achieve the desired level of diversification in such portfolio. To the extent a significant portion of a portfolio is invested in a few issuers’ securities, the performance of the portfolio could be significantly affected by the performance of those issuers. In addition, an investment portfolio with limited diversification may be subject to more rapid change in value than would be the case if the portfolio were required to maintain a wide diversification among industries, areas, types of securities and issuers, and will not have the protection against risk that diversification provides. Equity Risks. The value of equity securities generally will vary with the performance of the issuer and movements in the equity markets. As a result, a Client’s account may suffer losses if it invests in equity securities of issuers whose performance diverges from our expectations or if equity markets generally move in a single direction and the Client’s account has not been hedged against such a general move. To the extent a Client’s account invests in equity derivatives and private placements activities, the Client’s account will be exposed to risks that issuers will not fulfill their contractual obligations, such as delivering marketable common stocks upon conversions of convertible securities and registering restricted securities for public resale. Price Volatility. Equity securities are inherently volatile investments. Such volatility may result in the value of a portfolio holding such securities fluctuating from time‐to‐time more greatly than those of other portfolios which may hold fewer equity securities. There can be no assurance that our investment strategy, including our hedging techniques, or other investment strategies or techniques, will be effective in protecting our Clients’ accounts from such price volatility. Investments with Limited or No Liquidity. Our Clients’ accounts may take positions in certain securities that are relatively large as compared to the trading volume of such securities or overall market capitalization of the applicable issuers. Such positions may at times prove more difficult to sell in a timely or efficient manner and could thus impair to some extent the ability to fully realize portfolio gains or limit losses. We generally do not intend to limit investments to issuers of any minimum capitalization and may, in fact, focus upon smaller capitalization stocks when such securities appear to afford greater appreciation potential. Such stocks often have less liquidity than large capitalization issues. Call Options. The seller (writer) of a call option that is covered (e.g., the writer holds the underlying security) assumes the risk of a decline in the market price of the underlying security below the purchase price of the underlying security less the premium received and gives up the opportunity for gain on the underlying security above the exercise price of the option. The seller of an uncovered call option assumes the risk of a theoretically unlimited increase in the market price of the underlying security above the exercise price of the option. The securities necessary to satisfy the exercise of an uncovered call option may be unavailable for purchase, except at much higher prices, thereby reducing or eliminating the value of the premium. The buyer of a call option assumes the risk of losing the entire premium investment in the call option. Put Options. The seller (writer) of a put option which is covered (e.g., the writer has a short position in the underlying security) assumes the risk of an increase in the market price of the underlying security above the sales price (in establishing the short position) of the underlying security plus the premium received, and gives up the opportunity for gain on the underlying security if the market price falls below

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the exercise price of the option. The seller of an uncovered put option assumes the risk of a decline in the market price of the underlying security below the exercise price of the option. The buyer of a put option assumes the risk of losing the entire investment in the put option. Leverage; Interest Rates; Margin. (ACA very rarely uses these strategies). We expect to utilize leverage on behalf of our Clients’ accounts on a very selective basis, as we consider appropriate, primarily for investment purposes to increase investment positions or to make additional investments. Leverage may be employed by means of conventional margin arrangements, or through options, swaps, forwards and other derivative instruments (i.e., so called “synthetic” leverage). While leverage (including the use of derivatives) presents opportunities for increasing total return, it has the effect of potentially increasing losses as well. The effect of the use of leverage in a market that moves adversely to the investments of the entity employing the leverage, could result in a loss that would be greater than if leverage were not employed. In addition, the interest of borrowings will affect operating results. The use of short‐term borrowings may result in certain additional risks. For example, should the securities that are pledged to brokers to secure margin accounts decline in value, or should brokers increase their maintenance margin requirements (i.e., reduce the percentage of a position that can be financed), then borrower could be subject to a “margin call,” pursuant to which the borrower must either deposit additional funds with the broker or suffer mandatory liquidation of the pledged securities to compensate for the decline in value. Limitations on Shorting and Hedging Strategies. We may employ certain hedging techniques directed primarily toward general market risks. Hedging against a decline in the value of a portfolio position does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the overall portfolio value. Such hedge transactions, however, also limit the opportunity for gain if the value of the portfolio position should increase. In addition, the degree of correlation between price movements of the instruments used in a hedging strategy and price movements in the portfolio position being hedged may vary. Insufficient correlation between hedged and hedging positions may not only result in failing to protect against risks sought to be hedged but may increase the magnitude of overall loss in the event of losses in the hedging positions. For a variety of reasons, we may not seek or be able to establish a sufficiently accurate correlation between such hedging instruments and the portfolio holdings being hedged. Moreover, we may not necessarily endeavor to hedge a portfolio whatsoever. In the event hedging is utilized, it will be employed, in general, solely as a technique to limit certain market risks. As a general matter, a portfolio will still be exposed to basic issuer risk and other risks attendant to its investment strategy and to positions, which risks will not be generally hedged.

ACA provides investment advice to the Fund and offers advice to Clients on the advisability of investing in the Fund. The nature of the conflict of interest resulting from this arrangement is further elaborated in Item 6 – Performance Based Fees and Side‐By‐Side Management, as well as the steps taken by the Firm to address those conflicts. D. ACA does not recommend or select other investment advisors for its Clients, nor does it have any other business relationships with other investment advisors.

Specifically, as described previously in Item 6 – Performance Based Fees and Side‐By‐ Side Management, ACA acts as the general partner to the Fund and offers advice to its Clients on the advisability of investing in The Fund. As this represents a conflict of interest, the Firm’s Code of Ethics places limitations upon the timing of trades in the Fund relative to those in Client accounts and requires ongoing review of trades to ensure compliance with these procedures. C. ACA buys or sells for its related persons securities that it also recommends to Clients. The Firm places such securities on its “Restricted List” and prohibits the purchase or sale of such securities by the Fund on the same trading day as any transaction in that security is effected for any other Client accounts. A record of all trades placed in Client accounts, including the Fund, is reviewed quarterly to ensure adherence to these procedures. D.

See paragraph C above.

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While there are numerous benefits to Clients relative to our exclusive use of Schwab Advisor Services as a broker‐dealer, there is also an incentive to select Schwab Advisor Services based upon our interests rather than our Clients’ interests.

The Custodian and Broker We Use

ACA does not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets for regulatory purposes if you give us authority to withdraw assets from your account (see Item 15 – Custody). Your assets must be maintained in an account at a “qualified custodian,” generally a broker‐dealer or bank. Except for an alternative investment position held in some Client IRA accounts which are custodied at Millennium Trust Company, we require that our Clients use Schwab Advisor Services as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab Advisor Services. will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we require that you use Schwab Advisor Services as custodian/broker, you will decide whether to do so and will open your account with Schwab Advisor Services by entering into an account agreement directly with them. We do not open the account for you, although we will assist you in doing so. If you do not wish to place your assets with Schwab Advisor Services, then we reserve the right to decline acceptance of your account. Not all advisors require their clients to use a broker‐dealer or custodian selected by the advisor. Even though your account is maintained at Schwab Advisor Services, we can still use other brokers to execute trades for your account as described below (see “Your Brokerage and Custody Costs”), although we do not actively seek to do so. The Fund’s assets are maintained at Northern Trust Securities, Inc. How We Select Brokers/Custodians We seek to use a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others:

Combination of transaction execution services and asset custody services, Capability to execute, clear, and settle trades (buy and sell securities for your account), Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.), Breadth of available investment products (stocks, bonds, mutual funds, exchange‐traded funds, etc.), Availability of investment research and tools that assist us in making investment decisions Quality of services, Competitiveness of the price of those services (commission rates, margin interest rates, other -12-

fees, etc.), Reputation, financial strength and stability, Prior service to us and our other clients, and Availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us from Schwab Advisor Services.

Your Brokerage and Custody Costs You are not charged separately for custody costs or brokerage costs on trades executed by Schwab Advisor Services. As described in Item 4 – Advisory Business, ACA sponsors a wrap fee program which provides the Client with investment advisory and brokerage execution and custody services for one all‐inclusive fee. We have determined that having Schwab Advisor Services execute trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select Brokers/Custodians”). Products and Services Available to Us from Schwab Advisor Services. As described above, ACA has an arrangement with Schwab Advisor Services through which Schwab Advisor Services provides us with Schwab Advisor Services “platform” services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support intermediaries like us in conducting business and in serving the best interests of our Clients but that may also benefit us. As part of the arrangement, Schwab Advisor Services makes available to us, at no additional charge to us, certain research and brokerage services, including research services obtained by Schwab Advisor Services directly from independent research companies, as selected by us (within specified parameters). These research and brokerage services presently include services such as mutual fund research and are used by us to manage accounts for which we have investment discretion. We may also receive additional services which may include software and technology. Without this arrangement, we might be compelled to purchase the same or similar services at our own expense. Because of receiving such services for no additional cost, we may have an incentive to continue to use or expand the use of Schwab Advisor Services . We examined the potential conflict of interest when we chose to enter the relationship with Schwab Advisor Services and have determined that the relationship is in the best interests of our Clients and satisfies our Client obligations, including our duty to seek best execution. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. ACA and Schwab Advisor Services are not affiliates. Since all our Client accounts use Schwab Advisor Services for custodial and brokerage services, there are no allocation issues related to benefits received because of our relationship with Schwab Advisor Services. Although ACA may from time to time receive client referrals from Schwab Advisor Services, any such client referrals are not a factor in our continued selection and recommendation of Schwab Advisor Services as broker‐dealer.

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Aggregated Trades

ACA may block trades where possible and when advantageous to Clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple Client accounts. Block trading allows the Firm to execute equity trades in a more timely, equitable manner. No Client will be favored over any other Client. Each Client that participates in an aggregated order will participate at the average share price for all Firm transactions in a given security on a given business day. ACA does not block trades of the Fund with those of other Client accounts.

Clients also receive a written quarterly report from ACA summarizing account activity and performance. Clients are urged to compare the statements from Schwab Advisor Services with the quarterly reports received from us.

These reports contain a legend that urges Clients to compare the information contained in our report to the statements they receive directly from the custodian. ACA also acts as both general partner and investment adviser to the Fund, and is deemed to have custody of the assets of the Fund. As required, the Fund is audited annually by a Public Company Accounting Oversight Board (PCAOB) registered and inspected accounting firm, and the audited financial statements are delivered to all investors of the Fund within one hundred twenty (120) days of the end of the Fund’s fiscal year (the Fund’s fiscal year end is March 31 of each year).