A. Firm Description GUARDSMAN PRIVATE CAPITAL MANAGEMENT, INC. (“GUARDSMAN”) was founded in 2014 and is organized as a corporation under the laws of the state of Florida. GUARDSMAN is based in Sarasota, Florida, and is 100% owned by Jeffrey McCurdy. One or more investment advisory clients of GUARDSMAN previously received investment advisory services from Guardsman Wealth Management, Inc. (also 100% owned by Jeffrey McCurdy), which was founded in 2001 and was previously exempt as an investment adviser with the SEC and State of Florida. All investment advisory services of Guardsman Wealth Management, Inc. have been transferred to, and are now exclusively provided by, GUARDSMAN and such clients no longer receive any investment advisory services from Guardsman Wealth Management, Inc., which currently only provides, as described more fully under Item 10.C below, family office administration and real estate services and no longer acts as an investment adviser. Guardsman Wealth Management, Inc. currently provides such services to one or more clients of GUARDSMAN. B. Types of Advisory Services GUARDSMAN is a boutique investment advisory practice that provides highly customized investment management and certain family office services to a limited number of ultra-high net worth individuals and families, trusts, individual retirement accounts, estates, charitable organizations and private entities. Advice and services are provided through consultations with the client and may include: discretionary and non-discretionary portfolio management of marketable securities, portfolio construction, trading, tax-loss harvesting, due diligence on private equity investments, negotiation of investment terms, general strategic asset allocation, portfolio rebalancing, financial planning, estate and wealth transfer planning, investment manager due diligence and monitoring, financial reporting, and hedging strategies. The President of GUARDSMAN is also actively engaged, in his personal capacity as well as through related entities, as manager and/or corporate officer of numerous family investment entities owned or controlled by advisory clients. We treat these services provided as activities of GUARDSMAN. GUARDSMAN is strictly fee-only and does not receive commissions for purchasing or selling stocks, bonds, mutual funds, limited partnerships, annuities, insurance or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions or other transaction-based compensation in any form are accepted. GUARDSMAN does not act as a physical custodian of client assets and the client always maintains asset

control. All client assets are held by a “qualified custodian” as that term is defined in the Advisers Act Rule 206(4)-2. GUARDSMAN places trades for clients under a limited power of attorney. C. Tailored Relationships GUARDSMAN tailors its advisory services to the individual needs of its clients. GUARDSMAN exercises full investment discretion over the accounts of certain clients. Clients may impose restrictions on GUARDSMAN’s investment discretion. Some restrictions may include, but are not limited to, ESG considerations, fixed income securities, credit ratings, and taxable versus nontaxable characteristics. Such investment guidelines and restrictions must be provided to GUARDSMAN in writing. Such restrictions may adversely impact performance. With regard to certain clients, GUARDSMAN will not have discretionary authority over the client's assets. GUARDSMAN will review the client's investments and will provide investment advice and make recommendations to the client whenever, in GUARDSMAN's judgment, developments so warrant; however, the implementation of all investment decisions will require the client's prior approval or instructions. Such clients remain solely responsible for all investment decisions made with respect to any such client's account. As requested by client, GUARDSMAN provides services to its individual-clients that are akin to a "Family CFO" by which GUARDSMAN will assist its individual-clients with qualitative, non-financial services, including a discussion of estate planning. In this capacity, GUARDSMAN, through Jeffrey McCurdy, may serve as manager of a family company and operate the company or execute documents in accordance with an entity's operating agreement, clients' instructions, and pre-approval. GUARDSMAN does not provide legal advice. GUARDSMAN may consult or interact with third parties who perform components of traditional financial planning for GUARDSMAN's clients. D. Assets Under Management As of December 31, 2023, GUARDSMAN managed approximately $147,875,659 in assets, approximately $132,799,496 on a discretionary basis and $15,076,163 on a non-discretionary basis. These are regulatory assets under management (i.e., those assets for which GUARDSMAN provides continuous and regular supervision or management services). Some clients, which may include family clients (unrelated to Jeffrey McCurdy) and one or more of their affiliated family investment entities, receive advisory services but not continuous and regular supervision or management services; therefore, any assets related to such advisory services are not calculated toward GUARDSMAN’s regulatory assets under management.