White Pine Capital, LLC (“WPC”) is an SEC registered investment advisory firm formed in March 2000. WPC provides fee‐based discretionary investment advisory services, defined as making investments for clients based on the individual needs of the client. Michael Wallace, Timothy Madey, WPC’s principals, own 85% of the company. The balance of the company’s ownership is shared among Charles Bellows, Barbara Hardy, and Allison Little. As of 12/31/2023, WPC manages approximately $325 million in discretionary client assets. WPC clients include institutional accounts (corporate, pension and profit‐sharing accounts, endowments, foundations, and Taft‐Hartley (union) plans), family offices and high net worth individuals. All clients must sign a written advisory agreement. The investment advisory agreement may be terminated by either party with 30 days written notice. WPC’s investment strategies include Small Cap Equity and Wealth Management Services. The Wealth Management Services strategy uses a broad customizable approach encompassing 11 asset classes that often includes both taxable and tax–exempt accounts in a client’s household. All accounts are separately managed. Generally, all accounts have a written statement of investment guidelines. WPC tailors investments based on clients’ requests for various reasons including, but not limited to, cash flow needs, risk tolerance, tax planning, and/or time horizon primarily by adjusting the asset classes and/or mix of securities within the client’s portfolio. Clients may impose reasonable restrictions on investments for their account, which must be in writing. WPC manages institutional accounts based upon a real‐time model account in the client’s chosen investment strategy. WPC provides portfolio management services under "wrap fee" arrangements offered by unaffiliated broker dealer sponsors. WPC invests wrap fee accounts using the same investment process and/or real time model portfolio that is used for non‐wrap fee accounts. The broker dealer recommends us as an investment adviser for a certain strategy or strategies, pays our management fee on behalf of the client, monitors and evaluates our performance, executes the client's portfolio transactions without commission charge, and provides custodial services for the client's assets. These services, or any combination of these or other services, are provided for a single, all‐inclusive

fee paid by the client to the broker dealer. Our investment advisory fee under such a "wrap fee" arrangement sometimes differs from that offered to other clients in the same strategy. Transactions are executed "net", i.e., without commissions, and a portion of the wrap fee is generally considered as being in lieu of commissions. The program sponsor determines the broker dealer through which transactions must be executed. In these wrap fee arrangements, WPC is unable to seek best price and better execution by placing trades with other brokers and dealers. While it has been our experience that broker dealers with whom it presently deals under the clients' wrap fee arrangements generally can offer best price for transactions in listed equity securities, no assurance can be given that this will continue to be the case with those or other broker dealers who offer wrap fee arrangements. Accordingly, the client may wish to verify that the broker dealer offering the wrap fee arrangement can provide adequate price and execution of most or all transactions. The sponsoring broker dealer provides additional information about their program in their Wrap Fee Program Brochure (Form ADV Part 2A, Appendix 1). WPC has entered into a service agreement with Pontera for clients with assets held away at other qualified custodians, or “Held‐Away accounts.” These are primarily 401(k) accounts. For those clients who have elected to use this service, they must also enter into a separate user agreement with Pontera Solutions Inc. (“Pontera”), a third‐party order management system software provider. Once the client has established an online Pontera account and linked their Held‐Away account to Pontera, WPC is able to use Pontera’s system to view and manage the account. The client’s individual investment strategy is tailored to their specific needs and may include some or all the securities made available. Portfolios are designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced. WPC is not affiliated with the platform in any way and receives no compensation from them for using their platform. WPC does not have access to any client passwords as a result of this arrangement, nor the ability to withdraw or direct the disposition of securities or funds.