FIRM DESCRIPTION Dubeau Capital USA, Inc. (hereinafter referred to as “Dubeau Capital,” “we,” “us,” “the Firm,” or “our Firm”) is a private corporation, organized in under the laws of Canada, with its principal office located in Quebec City, Quebec Canada. The principal owners of the Firm are Hugues Dubeau, Stephane Dubeau and Eric Caouette. Mr. H. Dubeau also serves as Chief Compliance Officer of the Firm. As a registered investment adviser, we are a fiduciary to you, our client, meaning we have a fundamental obligation to act and provide investment advice that is in your best interest. Should any material conflicts of interest exist that might affect the impartiality of our investment advice, they will be disclosed to you in this Brochure. We urge you to review this Brochure carefully and consider our qualifications, business practices and the nature of our advisory services before becoming our client. As of November 15, 2023, Dubeau Capital had USD 29,103,000 in assets under management (AUM) on a discretionary basis, as compared to AUMs of USD 27,046,000 as of November 30 2022, an increase mainly due to market conditions. Clients may request more current information at any time by contacting our Firm. ADVISORY SERVICES Dubeau Capital provides investment management services to our clients. In connection with our investment management services, Dubeau Capital provides advice with respect to stocks and bonds. Our advice is generally limited to these types of investments, but we reserve the right to advise or not advise our clients on certain investments should we deem it appropriate based on their particular circumstances. Dubeau Capital’s advisory services are tailored to the needs of our clients based on their individual investment objectives, risk tolerance, cash or income needs, and any investment restrictions. Although Dubeau Capital seeks to accommodate any reasonable investment restrictions or guidelines set by our clients, we may decline to accommodate certain investment restrictions that are incompatible with our firms’ investment philosophy or that may have an adverse effect on

our ability to manage your account. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client’s investment guidelines, we will maintain annual contact with our clients in terms of portfolio construction, transactions and performance. Dubeau Capital enters into formal written agreements with our clients setting forth the terms and conditions under which we will provide our advisory services (the “Investment Management Agreement”). The Investment Management Agreement sets forth the scope of the services to be provided and the compensation we receive from the client for such services. The Investment Management Agreement may be terminated by either party in writing at any time by giving thirty (30) days signed written notice to the other party. Our advisors offer the advisory service described below to our clients: Investment Management Dubeau Capital provides investment management services on a discretionary basis to our clients. Discretionary authority means clients grant our firm the ability to utilize discretion in managing their investment account(s). Specifically, the client grants our firm full power to direct, manage, and change the investment and reinvestment of the assets in the account, the proceeds and any additions. Our authority over clients’ investments includes discretionary authority to purchase and sell securities for the client’s account and to give instructions concerning these transactions to the qualified custodian with which the clients’ accounts are held. We are not required to first consult with clients before placing any specific order or obtain specific authorization from the client for each specific transaction. We receive discretionary authority from our clients through our advisory agreement at the outset of our advisory relationship. Important Note: It is the client’s responsibility to ensure that Dubeau Capital is promptly notified if there are ever any significant changes to their financial situation, goals, objectives or needs so we can review our previous recommendations and make any necessary adjustments.