A. Description of Advisory Firm Wittenberg Investment Management, Inc. is an SEC-registered investment adviser with its principal place of business located in Massachusetts. Wittenberg Investment Management, Inc. began conducting business in 1988. The firm’s principal shareholder is Joel B. Wittenberg, its President and Chief Compliance Officer. B. Advisory Services Offered Wittenberg Investment Management, Inc. provides investment advisory and portfolio management services and does not provide custody of securities or other administrative services. At no time will Wittenberg Investment Management accept or maintain custody of a client’s funds or securities. All client assets will be managed within a client’s designated brokerage account or accounts. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s personal investment policy and create and manage a portfolio based on that policy. We seek to determine each client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. After taking into account their investment needs and objectives, we endeavor to construct a diversified portfolio for each client. The portfolio may include the following types of investments:
• Stocks
• Bonds
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Warrants
• Money Market Funds Our investment strategy is primarily focused on the long-term

holding of common stocks, preferred stocks and bonds but we may buy, sell, or re-allocate positions that have been held for less than one year in an effort to meet the objectives of a particular client or due to market conditions. We may sell positions for reasons that include, but are not limited to, harvesting capital gains or losses, tax minimization, business or sector risk exposure to a specific security or class of securities, a change in a client’s risk tolerance, generating cash to meet the needs of a client, or to seek to decrease any risk deemed unacceptable for a client’s risk tolerance. We may employ cash as a possible hedge against a potential downward market movement; this may adversely affect the portfolio. Holdings in client accounts may differ from other client accounts with a similar risk tolerance due to many factors, including but not limited to a client’s need for income, liquidity, the timing of cash flows in or out of a particular account, portfolio concentration, investment restrictions imposed by the client, and the tax consequences of potential portfolio changes. Because different investments involve varying degrees of risk, they will only be purchased when consistent with the client’s stated investment objectives, tolerance for risk, liquidity and suitability. C. Availability of Customized Services for Individual Clients Each client has the opportunity to place reasonable restrictions on the types of investments to be held in his or her portfolio, subject to the acceptance of such restrictions by Wittenberg Investment Management, Inc. Such restrictions must be provided to our firm in writing. D. Wrap Fee Programs We do not manage or place client assets into any wrap fee program. E. Assets Under Management As of December 31, 2023, we were actively managing $359,877,380 of clients’ assets on a discretionary basis. We do not accept any assets for management on a non- discretionary basis.