Punch & Associates is an independent boutique investment adviser located in Edina, Minnesota, founded in February 2002. Punch & Associates is 100% employee owned; its principal owners are Howard D. Punch, Jr. (majority owner), Andrew J. Matysik, John C. Carraux, Jessica Johnson and Paul Dwyer. As of December 31, 2023, we had discretionary assets under management of $1,855,474,674. We offer two primary services to clients: Investment Management and Wealth Advisory. Investment Management We provide discretionary portfolio management services to private and institutional clients, based on the specific needs and objectives of each client. In addition, we serve as investment adviser and managing member to two private funds focused on micro cap investment opportunities (the “Micro Cap Fund”) and nano cap investment opportunities (the “Nano Cap Fund”, each a “Private Fund” and collectively the “Private Funds”). In managing portfolios, we incorporate an investment philosophy that, at its core, seeks to preserve and grow our clients’ assets. We are a multi-cap manager offering the following core strategies: 1. Income 2. Large Cap Equity 3. Small Cap Equity 4. Micro Cap and Nano Cap Equity (Private Funds) 5. All Cap Equity Our institutional clients generally hire us for a specific strategy or a subset of one of our existing strategies. Our private clients generally hire us to manage a substantial portion of their personal portfolio, where we believe one of the most important decisions involves the allocation of assets among different asset classes, supplemented by rigorous fundamental analysis which, in our experience, provides the key to successful security selection. We believe it is possible to achieve consistent investment returns over full market cycles by using a disciplined and opportunistic style of investing. When managing client portfolios, we will consider client-imposed restrictions on investing in securities or specific types of securities, as directed by clients and agreed to by us in writing. Clients may request us to manage assets within a donor advised fund. Under these arrangements, the client selects the donor advised fund to which he or she makes

a charitable contribution. At the donor advised fund’s sole discretion and subject to its policies and restrictions, the donor advised fund may permit an individual to select an investment advisor to manage those assets. In these cases, the donor advised fund becomes the client, as the donor advised fund owns the assets donated by the individual. The selection of a donor advised fund and the decision to make a charitable donation from the client’s investment portfolio rests solely with the client. Punch & Associates maintains relationships with a select number of donor advised funds, but does not have a formal referral arrangement in place with any donor advised fund and does not receive compensation for referrals to any donor advised fund. See Items 7 and 10 for a discussion of relationships we maintain with other entities. Punch & Associates has entered into an agreement in which we serve as a non-discretionary sub- adviser of an open-end, management investment company registered under the Investment Company Act of 1940, as amended. Pursuant to this agreement, we provide an unaffiliated third- party Adviser (the “Manager”) with a Model Portfolio of small cap equity securities on a regular basis. The Manager has discretion to implement the Model Portfolio and is fully responsible for managing client transactions. Wealth Advisory In connection with our Wealth Advisory service, our Wealth Strategies Group oversees clients’ overall financial situations on an ongoing basis, striving to assist clients in addressing their important financial issues. Our process begins with a “Discovery Meeting” where we assess the individual’s or family’s financial situation, both qualitatively and quantitatively. We examine the client’s current situation, future goals, investment objectives and risk tolerance along with their time horizon and income needs. Then, we develop a plan and a timeline, after which we begin implementing and monitoring the plan through frequent and detailed communication in an effort to ensure we are aware of events and changes that will require adjustments. Our Wealth Advisory service is customized to each client’s specific needs and circumstances.