Overview of the Firm: Sparrow Capital Management, Inc. (“SPARROW”) is an independent, privately-owned investment advisor registered with SEC. SPARROW was established in 1988 by its President, Chief Investment Officer and Chief Compliance Officer, Gerald R. Sparrow, principal owner of SPARROW. SPARROW’s office is located in Saint Louis, Missouri. Investment Services: SPARROW provides investment advisory services for individuals, banks, corporations, employee benefit programs, estates, professional organizations and trusts, as well as Sparrow Fund L.P. ("SPLP" or the “Private Partnership”) and Sparrow Growth Fund (“Sparrow Fund” and together with SPLP, the “Funds”). We refer to persons or entities to which we provide investment advice as a “Client” or “Clients.” SPARROW reviews the investment portfolio of the Client, if any is submitted. Based upon the review and discussions with the Client, the Client’s financial needs and investment objectives are incorporated into the management agreement, and investments that are consistent with such financial needs and investment objectives are made. SPARROW tailors its advisory services to the individual needs of Clients. SPARROW will accept reasonable restrictions on investing in certain securities or types of securities. SPARROW, under the direct supervision of Mr. Gerald R. Sparrow, deals in advisory services in the range of $100,000 or more of assets for managed accounts; however, smaller accounts are accepted. Investment Services: SPARROW offers investment advice to certain clients through our participation in “wrap fee” programs. These programs are offered by brokerage firms to provide their clients with

access to non- affiliated investment advisers. There are potentially meaningful differences in the management of accounts participating in wrap fee programs, relative to other accounts managed by SPARROW. SPARROW will receive some portion of the wrap fees associated with participation in wrap fee programs. Investment Services: SPARROW has executed a Portfolio Manager Licensing Agreement with Covestor Limited. Covestor Limited (doing business as Interactive Advisors) is an SEC-registered investment adviser affiliated with Interactive Brokers LLC, the broker and custodian for some of our client accounts. Pursuant to that agreement, a SPARROW portfolio manager provides Covestor with information regarding the trading in an IB brokerage account owned by the portfolio manager. The SPARROW portfolio manager trades that account in accordance with a specific investment strategy. Based on this trading data, Covestor creates a portfolio discussed on its website, which Covestor clients may invest in, if Covestor deems it appropriate based on the client’s suitability profile. Covestor mirrors (subject to certain limits) the trading activity in the SPARROW portfolio manager’s brokerage account into the accounts of investing clients using Covestor’s proprietary replication logic. Neither SPARROW nor its portfolio manager offer any investment advice to Covestor clients, have discretionary trading authority over Covestor clients’ accounts, or know the identity or suitability profile of those clients. Assets under Management: As of December 31, 2022 SPARROW had assets of $178,973,509 in discretionary assets under management.