Genereux Investment Management, Inc. (“Advisor” or “we”) is an investment advisor registered with The Securities and Exchange Commission (“SEC” since November 2017) and notice filed with state securities regulators in Iowa (Since February 2012) and Colorado (Since February 2016) and other applicable states based upon where a client resides and the requirements of such state. We are a corporation formed under the laws of the State of Colorado and Mark A. Genereux is our sole owner. General Description of Primary Advisory Services We offer personalized advisory services including financial planning, consultations and investment management. The following are brief descriptions of our primary services. A detailed description is provided in Item 5, Fees and Compensation, so that clients and prospective clients (“clients” or “you”) can review the services and description of fees more thoroughly. Investment Management Services We offer investment management services by providing clients with ongoing and continuous portfolio management services that include, but are not limited to, risk management, investment policy, asset allocation, active or passive implementation, and performance monitoring. These services are typically implemented using exchange traded funds, mutual funds, separately managed accounts and individual securities. Depending on your needs, we may evaluate or recommend U.S. Government securities, tax- exempt municipal bonds and other fixed-income securities. This means that we continuously monitor a client’s account and make trades in that account when necessary. With your input, we attempt to construct a diversified portfolio of investments within our realm of expertise. Additionally, based on information provided by you, we prepare an evaluation of existing portfolio investments and provide recommendations for other investments as appropriate. We assist you in establishing a managed account(s) through a qualified custodian. We recommend the use of Charles Schwab Brokerage, Inc. Institutional Brokerage Group (“Charles Schwab”), although you are free to select any qualified custodian you wish by providing us with written direction. We require a minimum of $500,000 to establish an account. Charles Schwab or your selected custodian maintains custody of all your funds and securities. We do not act as custodian and do not have direct access to client funds and securities except for the ability to have advisory fees deducted by the custodian and paid to us with your prior written authorization. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We are granted trading authorization on your accounts and provide these management services on a discretionary basis only. This means we make all decisions to buy, sell or hold securities, cash or other investments in the managed account in our sole discretion without consulting with you before making any transactions. You must provide us with written authorization to exercise this discretionary authority, and you can place reasonable restrictions and limitations on the discretionary authority. See Item 16, Investment Discretion, for additional discussion on discretionary and non-discretionary authority. When Genereux Investment Management provides you with investment management services, our financial planning services are included. We can help individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning and other areas. Our role is to find ways to help clients understand their overall financial situation and help them set financial objectives. Our financial planning services focus on either a client’s overall financial situation or on specific areas of client concern. When appropriate and based on your identified needs, we can provide value-added financial planning services as part of our investment management services. Our financial planning services consist of discovery, analysis and recommendations pertaining to one or more of the following considerations, or based upon needs identified by you:
• Retirement Planning
• Analysis and recommendations relating to cash management issues
• Income distribution planning for retirement
• Employee stock option evaluation
• IRA or employer-sponsored retirement plan rollovers
• IRA required minimum distributions
• College funding for children or grandchildren
• Life Insurance and/or Disability Income Insurance
• Annuities
• Mortgages
• Estate Preservation & Wealth Transfer Planning
• Charitable & Philanthropic Planning We can provide you with oral or written reports on any of these areas selected by you. Retirement Plan Rollover Recommendations When we provide investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that Advisor is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way we make money creates conflicts with your interests so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, we must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of Advisor ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Advisor gives advice that is in your best interest;
• Charge no more than is reasonable for the services of Advisor; and
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by us, please know that Advisor and our

investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by us. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Advisor. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Advisor receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Advisor and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Advisor or our affiliated personnel. Online Financial Planning and Investment Consulting Services We offer online financial planning and consulting services as a separate service when you do not meet the $500,000 minimum to establish and maintain a managed account with Genereux Investment Management. Financial Planning Services Our financial planning services include: (a) An online financial plan for client on topics mutually agreed by client and the firm. We will proactively monitor client’s financial plan we prepare and provide recommendations to client when necessary. (b) We will be available for as-needed consultations, which are limited to consultations with us in response to a particular financial planning issue raised or request made by client. Client understands that it will be incumbent upon Client to identify to us those particular financial planning issues for which Client is requesting the advice or consultation of Genereux Investment Management. Client and Genereux Investment Management must mutually agree that we will provide consultations in response to such requests or issues raised by Client. The financial planning services will be based on Client's individual financial needs and circumstances. Client will provide us with all requested information and required documents that we may reasonably request in order to permit a complete evaluation and preparation of the recommendations for Client. We will not be responsible for the verification of the information and documentation provided by Client or Client’s outside professionals. Client will have the sole responsibility for determining whether to implement the financial planning recommendations. Client is not obligated in any manner to implement the financial planning advice through Genereux Investment Management. Investment Consulting Services Our investment consulting services involve Genereux Investment Management providing Client with portfolio review(s) and holding and/or performance report(s) and investment recommendations for specific account(s) of Client. Our services are limited to providing investment consultation regarding the account(s) specified in the Financial Planning and Investment Consulting Services Agreement. Client will be solely responsible for implementing (e.g., placing trades with the qualified custodian) any advice provided by us for the account(s). We will obtain from Client information to determine Client’s financial situation, investment objectives and risk tolerance. A specific investment strategy is crafted for Client and focuses on Client’s specific goals and objectives. The account(s) will be advised by us on the basis of Client’s financial situation, investment objectives and risk tolerance. Client may impose restrictions on our investment advice and recommendations, including specific investments and sectors which should be excluded. We will provide ongoing investment consulting by conducting portfolio review(s) of client’s account(s) with at least quarterly portfolio reviews. We may also provide consultations or investment recommendations for the account(s) in response to a specific request made by Client. Client is solely responsible for making investment decision related to the account(s) and providing trading instructions to the qualified custodian. Client authorizes qualified custodian(s) of the account(s) to provide Genereux Investment Management with online information (viewing only) about investments listed under the account(s). Specialization We specialize in asset allocation, risk management and small business retirement plans. Limits Advice to Certain Types of Investments. We provide investment advice on the following types of investments:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States government securities
• Option contracts on securities Although our advice is generally limited to the investment products previously listed, we reserve the right to offer advice on any product that may be suitable for each client’s specific circumstances, needs, goals and objectives. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, for more information. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the specific needs of the individual client. Clients are given the ability to impose restrictions on their accounts, including specific investment selections and sectors. However, we will not enter into an investment advisor relationship with anyone whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by Advisor The amount of client’s assets managed by Advisor totaled $121,894,320 as of November 14, 2023, with all accounts managed on a discretionary basis.