Rocky Mountain Advisers, LLC, an Alaska limited liability company, is an SEC-registered investment adviser with its principal place of business located at 2121 E. Crawford Place, Salina, Kansas 67401. The Adviser was formed in 2008 and began to actively conduct its investment advisory business in 2010. The Adviser’s principal equity holder (i.e., individuals and/or entities controlling 25% or more of the voting shares of the Adviser) is the Susan L. Ciciora Trust, an irrevocable trust domiciled in Alaska. The trust is the sole equity member of the Adviser, controlling 100% of the voting interests. ADVISORY SERVICES The Adviser offers the following advisory services to its clients: INVESTMENT SUPERVISORY SERVICES - INDIVIDUAL PORTFOLIO MANAGEMENT The Adviser provides continuous advice to private clients 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 investment allocation and create and manage a portfolio based on that allocation. During our data-gathering process, we determine the 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. Taking all information into consideration, we often create an investment allocation at the household level. We manage most of our private client advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following security types:
• Exchange-listed securities, including exchange traded funds (ETFs)
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Municipal securities
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• Interests in partnerships investing in oil and gas interests
• Certificates of deposit Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. FINANCIAL PLANNING SERVICES The financial planning services provided by the Adviser’s investment advisor representatives (“Advisory Representatives”) involves a number of different services, depending upon the needs and desires of the client. Not all Advisory Representatives will offer financial planning services or the same types of financial planning services. The services offered through Advisory Representatives include, but are not limited to, financial consultation services, portfolio reviews, retirement projections, asset allocation advice, estate tax projections, survivor income projections, education funding, insurance reviews, and disability income analysis. Advisory Representatives may offer additional services to particular clients. The client may include their other advisors, such as attorneys or accountants, in meetings with Advisory Representatives. Financial plans prepared by Advisory Representatives consist of various observations, assumptions, strategies, and recommendations. The recommendations noted in the plan will be implemented at the discretion of the client. Clients may choose to implement all, some or none of an Advisory Representatives’ recommendations. Clients also will have the discretion to implement the plan through any advisor or financial firm chosen by the client. The specific services to be rendered by an Advisory Representative will be described in a written contract between the Adviser and the client. Advisory Representatives provide only the services described in such contract. MUTUAL FUND PORTFOLIO MANAGEMENT The Adviser will enter into sub-advisory agreements with other registered investment advisers to investment companies registered under the Investment Company Act of 1940 to provide certain investment

management services to the adviser and its underlying fund(s). The Adviser manages, through sub-advisory relationships, the assets of SRH Total Return Fund, Inc., a closed-end investment company registered with the SEC under the Investment Company Act of 1940 (“STEW”) and SRH REIT Covered Call ETF (“SRHR”, together with STEW the “Funds”), a series of Elevation Series Trust (the “Trust”). The Trust is registered with the SEC under the Investment Company Act of 1940, as an open-end management investment company and the offering of SRHR’s shares is registered under the Securities Act of 1933, as amended. The Adviser continuously manages the Funds’ assets on a discretionary basis, based on the investment goals and objectives as disclosed in the Funds’ respective registration statements (as amended), statements of additional information, proxy statements, and periodic stockholder reports. Interested investors should refer to the Funds’ public filings for important information regarding objectives, investments, time horizons, risks, fees, and additional disclosures. These documents are available online at the Funds’ website (www.srhfunds.com) or the SEC's EDGAR website (http://www.sec.gov/edgar/searchedgar/webusers.htm). Prior to making any investment in the Funds, investors and prospective investors should carefully review these documents for a comprehensive understanding of the risks of investing in the Funds. INDEX PROVIDER The Adviser has developed and maintains the SRH US Quality Index (the “Index”). The Index is the basis for an exchange traded fund, the SRH US Quality ETF (“SRHQ”), which is managed by an unrelated party (the “ETF Provider”). In this capacity, the Adviser’s role is to compile, calculate, and maintain the Index. The Index was created to provide exposure to a diversified portfolio of U.S. companies featuring quality- and value-styled characteristics while maintaining overall market exposure close to that of widely-followed, broad-based U.S. equity benchmarks. The Index is constructed through the application of an objective, rules-based methodology created by the Adviser, which involves first defining the investable universe of securities, then screening the securities in the investable universe using value, growth, and quality metrics based on company valuation, revenue growth, and variability of such growth, respectively. Securities in the investable universe that pass each of these screens are included in the Index and are equal-weighted. The Adviser is solely the index provider for SRHQ and does not serve in an advisory or sub-advisory capacity. The Adviser receives a fee for providing the Index. AMOUNT OF MANAGED ASSETS As of December 31, 2023, the Adviser actively managed approximately $2.574 billion of clients' assets on a discretionary basis. Of this, as of December 31, 2023, $600.7 million was attributable to private clients, $1.92 billion was attributable to STEW, and $53.1 million was attributable to SRHR. As of December 31, 2023, the Adviser actively managed $0 of clients’ assets on a non-discretionary basis. ERISA/IRC FIDUCIARY ACKNOWLEDGMENT When the Adviser provides investment advice to a client regarding the client's retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act ("ERISA") and/or the Internal Revenue Code ("IRC"), as applicable, which are laws governing retirement accounts. The way the Adviser makes money creates some conflicts with client interests, so the Adviser operates under a special rule that requires it to act in the client's best interest and not put its interests ahead of the client's. Under this special rule's provisions, the Adviser must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of the client's when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that the Adviser gives advice that is in the client's best interest;
• Charge no more than is reasonable for the Adviser’s services; and
• Give the client basic information about conflicts of interest.