Bard Associates, Inc. (“BAI”) is an investment advisor registered with the Securities and Exchange Commission (“SEC”), under the Investment Advisors Act of 1940. We have been managing client money since 1983. BAI was founded and is led by Timothy B. Johnson. We invest your money in stocks, bonds, and other types of investments, using a long- term, buy-and-hold strategy. Each account is managed individually. When you open an account with us, you will fill out a “Confidential Client Profile,” which tells us about your financial goals, investment timeframe, liquidity needs, any restrictions on companies, industries, or types of securities you do not want to invest in, and, most importantly, your risk tolerance level. Your risk tolerance level is rated on a scale of 1 to 10. We consider all the information in your client profile before investing your money. Although we do not limit our advisory services to any type of security, our preference is to invest, for the “aggressive portion” of your portfolios, in the common stocks of smaller companies, because we believe that over longer periods of time smaller-company stocks provide higher returns than large-company stocks. Also, we believe that we can better assess the management of smaller companies and better analyze their financial statements, because they are simpler than those of large companies. We also invest in other instruments that we consider “defensive” in nature. These are appropriate for our more conservative clients and may include: Cash Equivalents Foreign Bonds Certificates of Deposit Real Estate Investment Trusts Government Bonds Royalty and Income Trusts Preferred Stocks Master Limited Partnerships Corporate Bonds Foreign Common Stocks Business Development Companies Commodities Utilities We target the mix of aggressive and defensive assets depending on your risk tolerance for each portfolio, as follows: % Invested % Invested In Other Risk in Micro-Cap Lower-Risk Tolerance Description Stocks “Defensive” Investments 1 No risk 0 100 2 Very Low Risk 0 100 3 Low Risk 0 100 4 Modest Risk 10 90 5 Medium Risk 20 80 6 Moderate Risk 30 70 7 Significant Risk 45 55 8 High Risk 60 40 9 Very High Risk 80 20 10 Maximum Risk 100 0 These are targets, not strict guidelines. We calculate and monitor this mix on an ongoing basis,

managing your portfolios with these targets in mind. The actual mix of assets may vary from these targets for a variety of good reasons. The most common reason for this is if we manage a given portfolio to the defensive side of your guidance to lower risk. Also, major cash flows, in or out, can temporarily affect the asset mix of any portfolio, and it may take time to adjust it. Portfolio Monitoring Service We also provide a portfolio monitoring service to some clients. If you choose this service, we will track one or more portfolio(s) that you manage. Every quarter, we will send you an evaluation of your portfolio(s), along with performance statistics for the quarter and year- to-date period. We can do this more frequently on your request. After the year ends, we will send you a tax package (if the account is taxable), which will tell you the capital gains, dividends, and interest for the year. Also, once each year, we will send you an “Account History,” which shows the history, year-by-year, of each account you manage. There is no extra charge for this service. Non-Discretionary Portfolio Management Service We provide a special non-discretionary portfolio management service to a few clients. With this service, we provide the research, recommendations, and, often, execution of buying and selling investments, but the client makes the decision of what to buy or sell and when to do so. This constitutes regular supervision of accounts containing non- discretionary assets, so we include it in our reporting of same under Amount Under Management below. The fee for this service is negotiated with each client. We have no clients using this service as of 12/31/2022. Bard Micro-Cap Value Fund At the end of 1999, BAI began offering the Bard Micro-Cap Value Fund, L.P. to clients. This is a limited partnership that invests in the smallest of companies (micro-caps) to achieve long-term capital growth. It often holds these stocks for years, during which period the companies may have grown beyond micro-cap size. BAI is the general partner of this partnership. We will provide you with a Private Offering Memorandum if you want to consider investing in this fund. This fund may not be available to everyone because of various state laws, investor limitations, and other factors. Other Investments We do not participate in any wrap fee programs. Amount Under Management We managed $309,851,664 of our clients’ money as of 12/31/2022 on a discretionary basis. BAI’s clients own many other self-managed accounts for which BAI provides only a portfolio monitoring service, or, in some cases, no service.