TRADEWINDS ASSET MANAGEMENT, LLC MARCH 2024 | PAGE 4 want TradeWinds engaged for these services, and if so, must provide TradeWinds third-party access to the investments. TradeWinds will not hold itself out to the public as engaging in brokerage activities. TradeWinds and the Agencies are separate and unrelated entities. As of December 31, 2023, we managed $131,640,422 on a discretionary basis. Investment Management Services: TradeWinds charges advisory fees (“Advisory Fees”) for Investment Management Services which are calculated as a percentage of assets under management (“Assets”). Our Standard Advisory Fee schedule is as follows. Asset Under Management Advisory Fee (annual) $0 to $499,999 1.50% $500,000 to $999,999 1.35% $1,000,000 to $1,999,999 1.25% $2,000,000 to $2,999,999 1.00% $3,000,000 to $3,999,999 0.95% $4,000,000 to $4,999,999 0.90% Over $5,000,000 0.85% The Advisory Fee is calculated quarterly and in advance based upon the value of the Assets in the client’s account at the beginning of each calendar quarter. The Assets include all positions in the accounts, cash, declared and paid dividends, accrued income and interest payments, unless specifically excluded or restricted from billing in writing by agreement with the client. We may have clients on a lower fee schedule and our Advisory Fees may be negotiated based on the individual client circumstances, familial relationships, complexity of relationship, existing client, etc. Our advisory agreement fully discloses our Advisory Fee and gives us authorization to debit our Advisory Fee directly from each client’s account. The Advisory Fee schedule set forth above is for our standard Investment Management Services. Additionally, we offer three investment strategies (each, a “Strategy”) outside our Investment Management Services, where clients may invest some or all of their account. Although subject to change, the current Strategies offerings are the Active Fixed Income Strategy (1.00% max annual fee), the Targeted Growth Strategy (max annual fee 1.75%), and the Targeted ESG Strategy (max annual fee 1.75%). Additional strategies may be developed in addition to those noted above. Any decision to invest funds into Targeted Growth or Targeted ESG Strategies is solely the client’s decision, although in some cases we will move funds out of these two Strategies into our investment options for clients. In some cases where we believe it is appropriate for the client, we will move funds into the Active Fixed Income Strategy. Since the Advisory Fee for the Targeted Growth and the Targeted ESG strategies are higher than our Standard Advisory Fees, we have a conflict of interest to have clients move funds into these Strategies, which is why we will not move funds into these investments without first discussing the risks and costs of these investment strategies with clients. In some cases, we have a conflict of interest to move clients out of the Active Fixed Income Strategy, because the fee is higher in other investments, so we will not move funds out of this Strategy without first discussing the move with the client. Clients should only select these Strategies if suitable for their investment objectives and risk tolerance. No portion of the Advisory Fee charged for Investment Management Services or for the Strategies shall be based on capital gains or capital appreciation of the Assets. Assets invested in a Strategy will be considered in establishing the AUM for determining the client’s Advisory Fee breakpoints. In addition to our Advisory Fee, clients are responsible for all transaction charges, custodial fees and other expenses charged and imposed by Schwab. Clients also may incur certain charges imposed at the fund level (e.g., management ASSETS UNDER MANAGEMENT MARCH 2024 | PAGE 5 fees and other fund expenses) by mutual fund and exchange traded funds (“ETFs”) in which we invest. Accordingly, clients should review these fees and our Advisory Fee to fully understand the total amount of the fees being paid. Clients may terminate the Advisory Agreement immediately upon written notice. Any unearned Advisory Fees will be rebated back to the account. Upon termination, the client is responsible for monitoring the securities in their account. TradeWinds will have no further obligation to act or advise with respect to those assets; provided, however, that the event of client’s death or disability, we will continue management of the account until we are notified of client’s death or disability, access is terminated by the custodian, or we are given alternative instructions by an authorized party. Through our Investment Management Services clients are provided Financial Planning services. There is not an additional charge for Financial Planning. The Hedge Fund: The Hedge Fund utilizes a fee structure that combines an asset-based management fee (“Management Fee”) and a performance-based fee (“Performance Fee”). Due to rules affecting the use of Performance Fees, only Limited Partners who are “qualified clients” will be permitted to purchase interests. In brief, to be a “qualified client”, an individual must have a net worth (excluding the equity in his/her principal residence) of $2.2 million or $1.1 million invested with TradeWinds. Further information on the fees charged by the Hedge Fund are as follows: Management Fee: The Management Fee is 2% per annum and based in each Limited Partner’s capital account in the Hedge Fund. The Management Fee is calculated and payable as to each Limited Partner in advance as of the beginning of each quarter based on the Limited Partner’s capital account at the beginning of the quarter. Limited Partners who are permitted by the General Partner to withdraw capital on a date other than the first day of a quarter are refunded a prorated Management Fee as to that withdrawal. The General Partner may, in its sole discretion, waive the Management Fee, in whole or in part, with respect to any or all Limited Partners in any accounting period. The management fee generally is not negotiable, although the General Partner reserves the right to offer reduced fees. Performance Fee: The Performance Fee is payable

only by Limited Partners who meet the eligibility requirements of a “qualified client” (defined in Item 6 below). At the end of each fiscal year (or a shorter period in certain circumstances), net profits for the year (if any) are allocated among the partners, and the General Partner receives a 20% "Performance Fee" as to each Limited Partner, subject to a “high water mark” (defined below). Specifically, after net losses previously allocated to the Limited Partners have been recovered (the “high water mark”), 20% of the remaining net profits, if any, are allocated to the General Partner. As noted above for Management Fees, the Performance Fee may be reduced at the discretion of the General Partner. The “high water mark” for a capital account is the net asset value (“NAV”) of such capital account immediately after the assessment of the most recent Performance Fee or, if the capital account has never been assessed a Performance Fee, the capital contribution that established such account. This provision ensures that the General Partner receives no Performance Fee with respect to any Limited Partner unless all unrecouped losses have been recovered and the value of such Limited Partner’s capital account is greater than the prior high NAV. The Performance Fee is debited from the capital account of each Limited Partner as of the end of each fiscal year (or upon the date of a capital withdrawal) and allocated to the capital account of the General Partner in accordance with the terms of the partnership agreement. Solely for purposes of computing the Performance Fee, net profits and net losses include realized and unrealized gains and losses. There are certain additional expenses associated with making investments on behalf of the Hedge Fund, such as commissions, spreads, mark-ups, interest on margin borrowing, costs related to short selling, clearing costs, transfer taxes, and custodian fees, There are certain other expenses that the Hedge Fund will incur, such as legal fees, tax preparation fees, fund administration fees, bookkeeping fees, auditing fees, consulting fees, and other operating expenses. These costs will be borne by the Hedge Fund regardless of the Hedge Fund’s profitability. The expenses of operating the Hedge Fund may be substantial, and may exceed its income, thereby requiring the difference to be paid out of the Hedge Fund’s assets, potentially reducing the partnership’s investment capital and potential for profitability. Item 12 further describes the factors we consider in selecting or recommending broker-dealers and determining the reasonableness of their commissions and other compensation. Limited Partners should consult the Hedge Fund’s offering documents for further information about the Hedge Fund’s fees and expenses. MARCH 2024 | PAGE 6 We believe our fees are competitive; however lower fees for comparable services may be available from other sources. We do not accept compensation or commissions for the sale of securities or other investments. As set forth elsewhere herein, Performance Fees will only be charged to certain eligible clients in accordance with the provisions of Rule 205-3 of the Investment Advisers Act of 1940, as amended. Our Investment Management Services clients do not incur performance-based fees. However, Limited Partners invested in the Hedge Fund will be subject to the Hedge Fund’s Performance Fees. Under current law, each person who is charged a performance fee must meet the definition of a “qualified client.” To be a “qualified client,” you generally must meet one of the following criteria:
• You have a net worth (or together with your spouse have a net worth) of at least $2.2 million (excluding the equity in your principal residence).
• Immediately after making your investment, you have at least $1,100,000 invested with TradeWinds. Performance-based fee arrangements create certain conflicts of interest. For example, under a performance fee arrangement, our compensation rises when the Hedge Fund’s investments profit by the amount of the profit. This variance may create an incentive for us to make investments which may be riskier or more speculative than those which would be made under a different fee arrangement. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. We manage both types of accounts. It is important for clients to understand these conflicts and to decide if the investment options are appropriate for their financial situation. Our goal is that our advice to each client remains at all times in each client’s best interest, disregarding any impact of the advice on us. We provide investment advice to individuals, high net worth individuals, insurance companies, and the Hedge Fund. We have an account minimum of $250,000 for our Investment Management Services. Our investment philosophy is based on technical analysis and trends based on the price of securities and asset classes and their performance relative to each other. We have a systematic and quantitative approach to investment decision- making that seeks to maximize growth potential over full market cycles. Additionally, we utilize numerous sources of information to provide advice, including but not limited to: financial newspapers and magazines, websites, research materials and software prepared by third parties, annual reports, prospectuses and filings with the SEC, company press reports, as well as our proprietary analysis of data and information. It is important to know that all methods of analysis include specific risks, including timing errors, inaccurate information, economic impacts, and other factors that can impact client investment performance. We may utilize long term purchases (securities held at least a year) and short-term purchases (securities sold within a year) when implementing investment advice. Short term purchases may increase costs and may also increase the tax obligation of the portfolio. Investments may also be made on margin, which may increase the costs due to the interest