First Growth Capital, LLC, a Maryland limited liability company, was founded in 2019 by David Reidy to provide investment advisory services to individuals, families and various entities. Additional services include: (i.) Financial Planning advice on a broad array of subjects impacting the finances of individuals and entities; and (ii.) investment advisory services. First Growth Capital is owned and operated by David Reidy. David has worked in the securities industry for over 15 years, starting in investment banking in New York City and spending time in the hedge fund industry as well. In 2012, he helped launch a multi- family office, The Parkridge Group, based in Pittsburgh, PA, to develop an in house investment advisory solution to complement the firm’s existing consulting business tailored to high and ultra- high net worth families. David’s tenure at The Parkridge Group spanned six years and he ultimately became the firm’s Chief Investment Officer and a Partner in the business. Over that time, David was instrumental in building Parkridge’s portfolio management business and in gathering over $200 million in assets under management. On December 23, 2023, David acquired The Parkridge Group and merged the firm with First Growth Capital, LLC. Advisory Services First Growth Capital LLC offers services specially tailored to the needs of each client in its Financial Planning and Investment Advisory divisions. The Financial Planning advisory service includes reviews and advice in subject areas pertinent to client finances including the establishment of investment objectives, allocation of funds to achieve goals and performance review and monitoring. Subjects are developed and prioritized through extensive interviews and data collection, preparation of short- and long-term cash flow projections, and risk tolerance assessment. First Growth Capital works closely with financial advisors and other professionals with whom clients may already have relationships to avoid redundancy, vet product pitches, manage processes and add value to those relationships by assuring comprehensive adherence to the client’s long-term goals. First Growth Capital also assists those clients who choose to implement advice independently do so by, for example, comparing and contrasting client-selected asset allocation models and security selection to other models for performance and cost control purposes, recommending certain investment products which may reasonably be expected to achieve client investment objectives and to tie investment planning into other financial planning topics. For example, portfolio allocations and rebalancing are done with an understanding of income tax consequences of various investment vehicles. First Growth Capital also provides, in conjunction with several custodians, an Investment Advisory Solution for those clients who choose to delegate responsibility for implementation of First Growth Capital’s investment planning recommendations to First Growth Capital. This involves discretionary investment management and advisory and sub-advisory services through separate accounts, mutual funds, private investment funds and/or collective investment trusts. First Growth Capital offers equity, fixed income, alternative, and derivative strategies that clients may choose from to meet their needs. Upon request, First Growth Capital will accommodate specific restrictions for accounts. Advisory accounts for which First Growth Capital has expressly agreed to serve as investment advisor pursuant to separate agreement are referred to as “Advisory Accounts” and include: (i) accounts that are managed by First Growth Capital and employ various investment management strategies based on clients’ stated investment objectives, risk tolerance and financial circumstances, and (ii) accounts that are managed on a discretionary or non-discretionary basis by external investment professionals with the oversight and consultation of First Growth Capital based on clients’ stated investment objectives, risk tolerance and financial circumstances. First Growth Capital devises proprietary strategies based on client goals to further their interests and executes these strategies with client consent and regular consultation. In addition to trading in securities, First Growth Capital may trade in more complex vehicles, such as derivatives, to provide additional benefit to its clients when appropriate. As First Growth Capital‘s client base and their needs are diverse, First Growth Capital may advise and manage client investments in private placements and non- traditional or non-market investments when and if these investments will benefit the client and/or at the client’s request. Commingled Vehicles In November of 2020, First Growth sponsored the launch the JCAM Dynamic Alpha Founders Fund LP, a Delaware Limited Partnership that serves as a hedge fund. JCAM is the fund’s sole investment advisor and its principal, David Reidy, is the fund’s General Partner. Non-Advisory Services Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, First Growth Capital may provide consulting services regarding non- investment related matters, such as estate planning, tax planning, insurance, etc. First Growth Capital does not serve as an attorney, accountant, or insurance agent, and no portion of First Growth Capital services should be construed as the same. To the extent requested by a client, First Growth Capital may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.). The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from First Growth Capital. Please Note: If the client engages any such recommended professional and a dispute arises thereafter relative to such engagement the client agrees to seek recourse exclusively from and against the engaged professional. Some implementation services are provided in-house, where expertise has been developed, while some implementation services outsourced to professional firms with various degrees of oversight from First Growth Capital. For example, simple income tax returns may be prepared by First Growth Capital but most are outsourced to a professional accounting firm where First Growth Capital has been able to obtain price discounts and priority servicing due to referral volume and relationship duration. Implementation for estate and other planning that requires legal services is always outsourced

to attorneys practicing law in the relevant fields. First Growth Capital’s revenue is in part derived from fees for consulting services, which may include an adjustment for investment advisory services, provided by First Growth Capital. All clients have the option to pursue investment strategies recommended by First Growth Capital through brokers or agents not affiliated with First Growth Capital. First Growth Capital does not accept performance-based fees of any kind. First Growth Capital also accepts no referral fees and no commissions, instead negotiating for lower external provider fees charged to clients where possible. Investment Services and Accounts First Growth Capital offers investment services and accounts through an agreement with several qualified custodians. These custodians are responsible for performance reporting and, in some cases, brokerage practices, on behalf of First Growth Capital’s clients. Investment Restrictions Clients may impose certain restrictions on the management of Advisory Accounts including restricting particular securities or types of investments provided that First Growth Capital accepts such restrictions. The Investment Advisory Agreement entered into between each client and First Growth Capital will document any accepted restrictions in writing. Clients should be aware that the overall financial performance of restricted Advisory Accounts might be lower than or otherwise differ from the performance of Advisory Accounts without restrictions. Client accounts will also be reviewed at least quarterly to make sure that stocks and other investments held therein are in accordance with clients’ specific investment restrictions and policies. Wrap Fee Program First Growth Capital does not participate in any a wrap fee programs. Assets Under Management As of December 31, 2023, First Growth Capital reports a total of $181,051,270 of regulatory assets under management on a discretionary basis. Miscellaneous Fee Differentials. First Growth Capital’s advisory fees are currently priced based upon various objective and subjective factors. As a result, First Growth Capital’s clients could pay diverse fees based upon the market value of their assets, the complexity of the engagement, and the level and scope of the overall investment advisory, financial planning and/or consulting services to be rendered. Because of these factors, the services to be provided by First Growth Capital to any client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly. Client Obligations In performing its services, First Growth Capital shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify First Growth Capital if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising First Growth Capital’s previous recommendations and/or services. Non-Discretionary Service Limitations Clients that determine to engage First Growth Capital on a non-discretionary investment advisory basis must be willing to accept that First Growth Capital cannot effect any account transactions without obtaining prior verbal consent to any such transaction(s) from the client. Thus, in the event that First Growth Capital would like to make a transaction for a client's account and client is unavailable, First Growth Capital will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s verbal consent. Unaffiliated Private Investment Funds First Growth Capital may also provide investment advice regarding unaffiliated private investment funds. First Growth Capital, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. First Growth Capital’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of First Growth Capital calculating its investment advisory fee. First Growth Capital ‘s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that First Growth Capital references private investment funds owned by the client on any supplemental account reports prepared by First Growth Capital, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. If no subsequent valuation post- purchase is provided by the Fund Sponsor, then the valuation shall reflect the initial purchase price (and/or a value as of a previous date), or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than original purchase price. The client’s advisory fee shall be based upon reflected fund value(s). Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by First Growth Capital) will be profitable or equal any specific performance level(s).