A. Pence Capital Management, LLC (the “Registrant”) is a limited liability company that was formed on October 20, 2015 in the state of Delaware. The Registrant became registered as an Investment Adviser Firm in December 2015. Eldon Dryden Pence III (also known as Dryden Pence) and Laila Marshall-Pence are the Registrant’s Principal Owners. Eldon Dryden Pence III is the Registrant’s Managing Member. B. As discussed below, the Registrant offers to its clients advisory and sub-investment services on a fee basis. The Registrant may also be engaged to provide investment consulting services on a separate fee basis. EXCHANGE TRADED FUND & SEPARATELY MANAGED ACCOUNTS The Registrant advises Separately Managed Accounts (“SMAs”) (accounts managed by an independent manager). When engaged as an investment manager for an SMA, the Registrant has the authority to direct trading activity within the account according to the SMA’s investment objective. SMAs generally allow for tax control of individual positions and the ability to block or restrict certain types of securities from purchase (i.e., tobacco, alcohol etc.). However, unlike UMAs, each SMA requires its own custodial account. The Registrant advises the AAM Transformers ETF, which tracks the Pence Transformers Index (“PTI”). The PTI follows a rules-based methodology that aims to target companies whose products and services show compelling potential to transform consumer behavior, technological innovation, and the global economy. The Registrant provides ongoing supervision of accounts. Before engaging Registrant to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. INVESTMENT ADVISORY SERVICES The Registrant provides advisory services on a separate fee basis to structure or design investment strategies for Unit Investment Trusts (“UITs”). The Registrant generally provides regular and ongoing advice with regard to the investment positions held within each UIT it advises. The Registrant may also be engaged to structure, design and advise on investment strategies for SMAs. When engaged to provide consulting services regarding SMAs, the Registrant will be responsible for the recommendation of changes within the SMA as well as prompting reallocations. Prior to engaging Registrant to provide investment advisory services on a stand-alone basis, the client will generally be required to enter into an agreement with Registrant setting forth the terms and conditions of the engagement, describing the scope of the services to be provided and the fee that is due from the client. In performing its services, Registrant shall not be required to verify any information received from clients or from the clients’ other professionals and is expressly authorized to rely thereon. MISCELLANEOUS Independent Managers. The Registrant may allocate a portion of a client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets. The Registrant shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that Registrant shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, Registrant’s investment advisory fee disclosed at Item 5 below. Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a non-discretionary investment advisory basis must be willing to accept that Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Therefore, in the event that Registrant would like to make a transaction for a client’s account, and client is unavailable, Registrant will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Separately Managed Account Programs. The Registrant may allocate a portion of a client’s investment assets among unaffiliated Separately Managed Account programs in accordance with the client’s designated investment objective(s). In such situations, the Separately Managed Account Manager shall have day-to-day responsibility for the active discretionary management of the allocated assets. The Registrant shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which the Registrant shall consider in recommending Separately Managed Account programs include the client’s designated investment objective(s) as applied to the Separately Managed Account program: management style, performance, reputation, financial strength, reporting, pricing, and research. Cash Positions. Registrant continues to treat cash as an asset class. As such, unless determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events

(there being no guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Registrant does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, Registrant shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Asset-Based Pricing Arrangements and Limitations. Registrant generally recommends that clients enter into an “Asset-Based” pricing agreement with the account broker- dealer/custodian. Under an asset based pricing arrangement, the amount that a client will pay the custodian for account commission/transaction fees is based upon a percentage (%) of the market value of the account, generally expressed in basis points and/or a percentage. One basis point is equal to one one-hundredth of one percent (1/100th of 1%, or 0.01% (0.0001). This differs from transaction-based pricing, which assesses a separate commission/transaction fee against the account for each account transaction. Account investment decisions are driven by security selection and anticipated market conditions and not the amount of transaction fees payable by you to the account custodian. Under either the asset-based or transaction-based pricing scenario, the fees charged by the respective broker-dealer/custodian are separate from, and in addition to, the advisory fee payable by the client to Registrant per Item 5 below. Registrant does not receive any portion of the asset-based transaction fees payable by you to the account custodian. You are under no obligation to enter into an asset-based arrangement, and, if you do, you can request at any time to switch from asset-based pricing to transactions-based pricing, However, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Thus, given the variances in trading volume, any decision by the client to switch to transaction-based pricing could prove to be economically disadvantageous. Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Registrant will conduct reviews on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the account’s investment objective. Based upon these factors, there may be extended periods of time when Registrant determines that changes to an account are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Client Obligations. In performing its services, the Registrant 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 its responsibility to promptly notify the Registrant if there is ever any change in an underlying client’s financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Registrant’s previous recommendations and/or services. Disclosure Statement. A copy of the Registrant’s written, Privacy Notice, Disclosure Brochure as set forth on Part 2 of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Sub- Advisory Agreement. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will obtain the underlying client’s investment objective from the client. Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. As of December 31, 2023, the Registrant had $1,082,682,405 in assets under management on a non-discretionary basis.