PMI is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) and is a corporation formed under the laws of Quebec, Canada.
• PMI is a wholly-owned subsidiary of Palos Capital Corporation. To the knowledge of PMI, the following persons own, beneficially or of record, directly or indirectly, more than 25% of the issued and outstanding voting securities of Palos Capital Corporation: (i) The Marleau Capital Corporation Inc. (55.08%); and (ii) Sopamy Consulting Inc. (27.79%).
• PMI was approved as an investment advisor by the SEC on July 29, 2019. As of December 31, 2023, PMI had a total of $128,122,803 in discretionary assets under management. The amount of discretionary assets under management includes the four Canadian investment companies managed by PMI. The fund assets total $126,080,032. For more information about the Investment Advisory Representative (IAR) providing your advisory services, the client should refer to the Brochure Supplement (also called the ADV Part 2B) for the IAR. The Brochure Supplement is a separate document that is provided by the IAR, along with this Brochure before or at the time the client engages the IAR. If the client did not receive a Brochure Supplement for the IAR, the client should contact PMI at 514-397-0188. Introduction The investment advisory services of PMI are provided to you through an IAR of PMI. Description of Advisory Services The following are descriptions of the advisory services of PMI offered to U.S. clients. PMI also provides services to several Canadian investment funds as part of its business conducted through its registration as an Investment Fund Manager with Canadian securities regulators. The Canadian investment funds are not available to U.S. clients. For more information about our services provided to Canadian investment funds please see Item 10 – Other Financial Industry Activities and Affiliations. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and PMI before we can provide you the services described below. Asset Management Services – PMI offers asset management services which are tailored to meet the needs of its individual clients, on a continuous basis, and seeks to ensure that such assets are managed in a manner consistent with the clients’ needs and objectives. PMI consults with clients on an initial and ongoing basis to assess the individual investment goals, time horizons, objectives, and risk tolerance relevant

to their portfolio. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Clients are advised to promptly notify PMI if there are any changes in their financial situation or if they wish to place any limitation on the management of their accounts. Clients may impose reasonable restrictions or mandates on the management of their accounts if PMI, in its sole discretion, determines that the conditions would not materially impact the management of a given strategy or prove overly burdensome to the Firm’s management efforts. Palos Management Inc. Page 5 Form ADV Part 2A Disclosure Brochure You must appoint our Firm as your investment adviser of record on specified accounts (collectively, the “account”). The account consists only of separate account(s) held by Custodian(s) under your name. The Custodians maintain physical custody of all funds and securities of the account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the account. The account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the account. Non-Discretionary Management: When the client elects to have PMI manage their assets on a non- discretionary basis, PMI will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, PMI will obtain prior client approval on each and every transaction before executing any transaction. Discretionary Management: When the client elects to have PMI manage their assets on a discretionary basis, the client will sign a limited trading authorization or equivalent allowing PMI to determine the securities to be bought or sold and the amount of the securities to be bought or sold. PMI will have the authority to execute transactions in the account without seeking client approval on each transaction. It is important that you understand that we manage investments for other clients and can give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we can buy, sell or recommend for any other clients or for our own accounts.