Summit Creek Advisors, LLC (referred to as “SCA”, or “we” throughout this document) is an investment adviser registered with the United States Securities and Exchange Commission. SCA is a limited liability company formed under the laws of the state of Minnesota. SCA offers investment advisory services by providing management of equity accounts for clients through its Small Cap Growth and SMid Cap Growth portfolio programs (collectively, “Portfolio Management Services”) and by providing trading recommendations to certain institutional clients. SCA has been registered as an investment adviser since August 11, 2009. Our Principal Owners and Management SCA is owned by Joseph John Docter and Adam Nathan Benson. John Crowther, Co-Portfolio Manager of the SMid Cap Growth strategy of the firm, is also a shareholder of the firm, owning a small amount of non-voting shares representing 7.4% of the total shares outstanding. The major decisions of a strategic and administrative nature for the firm are made jointly by Mr. Docter and Mr. Benson, Principal Owners and Portfolio Managers. The Chief Compliance Officer, Andrew Rank, is also involved in strategic and administrative decisions that have an impact on the firm’s compliance program. Client Assets Managed by Summit Creek Advisors As of December 31, 2023, SCA maintained 23 client relationships totaling 34 individual accounts. These individual accounts are comprised of corporations, pooled investment vehicles, pension and profit-sharing plans, charitable organizations, banking institutions, state or municipal government entities, a collective investment trust (“CIT”), high net worth individuals, and other individuals. The amount of client assets managed by SCA totaled $763,042,111 as of December 31, 2023. All of these assets are managed on a discretionary basis. In addition to the client assets managed by SCA, SCA provides recommendations and updates to certain institutional/corporate client assets. Since for these certain assets, the institutional/corporate clients who receive recommendations and updates from SCA are responsible for evaluating the investment recommendations provided by SCA, for accepting or rejecting the investment recommendations, and for implementing trades for these institutional/corporate clients’ own account or using the trade recommendations provided by SCA as a tool to provide investment management services for their own clients, the assets receiving this service from SCA are not considered regulatory assets under management. Additionally, these assets are not considered to be managed on a non-discretionary basis. However, such assets are considered to be part of the total assets receiving advisory services from SCA. The total amount of assets receiving advisory services from SCA as of December 31, 2023 is approximately $967,045,449, with $763,042,111 of those assets considered to be regulatory assets under management and $204,003,338 not considered regulatory assets under management but are assets that receive ongoing investment recommendations from SCA. Advisory Services Offered Summit Creek Portfolio Management Services SCA manages equity accounts for client accounts consisting of corporations, pooled investment vehicles, pension and profit-sharing plans, charitable organizations, banking institutions, state or municipal government entities, a CIT and high net worth individuals utilizing its Portfolio Management Services. Each portfolio is managed within the investment parameters established by the client. Each client is responsible for evaluating the risk relating to the investment parameters. All clients are required to furnish a written statement of investment guidelines to SCA prior to inception of account management. SCA has established Standard Investment Guidelines that are typically used for each of the Portfolio Management Services. After a determination by the client that SCA’s approach is appropriate for them, the client’s account will be managed based on the portfolio’s goal (i.e, the goal of the Small Cap Growth or SMid Cap Growth portfolio) rather than on each client’s individual needs. However, each client will have the opportunity to place reasonable restrictions on the types of investments to be held in the client’s account. If a client has contracted for our management services, SCA handles all trading and investing for the client. Summit Creek Model Portfolio Strategist Services SCA offers Model Portfolio Strategist Services (“Strategist Services”) to certain institutional/corporate clients. When providing Strategist Services, SCA provides securities recommendations and updates to institutional/corporate clients with respect to model portfolios maintained by SCA for the Small Cap Growth and SMid Cap Growth strategies. Such recommendations and updates are made available to those clients on a daily basis. Securities recommendations and updates provided to clients utilizing the Strategist Services reflect the model portfolio positions as of the previous business day’s market close. Institutional/corporate clients which receive recommendations and updates from SCA are responsible for evaluating the investment recommendations provided by SCA and for accepting or rejecting the investment recommendations. Institutional/corporate clients are responsible for implementing trades for their own accounts. If they are using the trade recommendations provided by SCA as a tool to provide investment management services for their own clients, then those clients are responsible for implementing trades for their investment management clients. For clients who have contracted for Strategist Services, SCA is not responsible for implementing any trade recommendations. For more information on the Strategist Services, please see Item 12. SCA does not manage the investment assets for the institutional/corporate clients who contract for Strategist Services. Except for being apprised of the total assets under management utilizing the Strategist Services for billing purposes, SCA does not collect any information regarding, or have any responsibility with respect to, the institutional/corporate clients’ investment management of their own clients. Each institutional/corporate client is responsible for evaluating the risk relating to its investment parameters and, as noted above, for making its own management decisions and doing the trade implementation for any clients or accounts for which it is responsible for providing investment management services. For the Strategist Services, SCA uses the standard investment guidelines described below for each client account unless there is a written agreement between SCA and the client specifying that the individual client’s account guidelines make an exception to these standard investment guidelines. Retirement Plan Services SCA offers its Portfolio Management Services to clients that are retirement plan sponsors. SCA acknowledges that in performing the Portfolio Management Services described above that SCA is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”). SCA will act in a manner consistent with the requirements of a fiduciary under ERISA when providing

such services to any client that is a retirement plan sponsor. If SCA is providing Portfolio Management Services to a client that is a retirement plan sponsor, SCA acknowledges that in addition to acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA, SCA is also acting as a fiduciary with “investment manager” fiduciary responsibilities as defined under Section 3(38) of ERISA to the extent SCA has agreed to provide discretionary management of designated assets of that client that are held in an ERISA qualified plan. Per the agreement with the client, SCA has no responsibility and will not (a) exercise any authority or control respecting disposition of assets of the client’s retirement plan except as authorized to provide discretionary management of assets of the client’s retirement plan, or (b) have any discretionary authority or discretionary responsibility in the administration of the client’s retirement plan or the interpretation of the client’s retirement plan documents. SCA does not serve as administrator or trustee for any retirement plan. SCA does not act as custodian for any client account or have access to client funds or securities. SCA will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to the client any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or plan administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the agreement that is required for the plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If SCA makes an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), SCA will disclose to the client the correct information as soon as practicable, but no later than thirty (30) days from the date on which SCA learns of such error or omission. Employee Accounts SCA manages three accounts which were established by the Principal Owners and founders of the firm to create performance track records for the managed strategies (“Founder Accounts”). Other employees have also established accounts that are managed by SCA (together, with the Founder Accounts, “Employee Accounts”). Trading within these accounts mimics the investment decisions made for the Small Cap Growth and SMid Cap Growth Strategy clients, as well as the recommendations provided to clients utilizing Strategist Services. Each Employee Account adheres to the Standard Investment Guidelines, as described below. Investment Guidelines As stated above, for both the Summit Creek Portfolio Management Services and the Summit Creek Strategist Services, SCA uses the Standard Investment Guidelines described below for each client account unless there is a written agreement between SCA and the client specifying that the individual client’s account guidelines make an exception to these Standard Investment Guidelines. Standard Investment Guidelines (for Small Cap Growth Portfolio Management & Small Cap Growth Portfolio Strategist Services) 1. 5% maximum cash. 2. 45-55 holdings. 3. 5% maximum exposure per holding at market price. 4. Less than 10% at market price in securities domiciled outside of the U.S. 5. Holdings domiciled outside of U.S. must actively trade on NYSE or NASDAQ. 6. Less than two times Russell 2000 Growth sector weight, with 40% maximum exposure to any sector. 7. Less than 20% of portfolio in stocks larger than the largest company in the Russell 2000 Growth. SMid Cap Growth Investment Guidelines SCA uses the SMid Cap Growth Investment Guidelines described below for each client account that has elected to participate in the SMid Cap Growth portfolio program unless there is a written agreement between SCA and the client specifying that the individual client’s account guidelines make an exception to these SMid Cap Growth Investment Guidelines. 1. 5% maximum cash. 2. 45-65 holdings. 3. 5% maximum exposure per holding at market price. 4. Less than 15% at market price in securities domiciled outside of the U.S. 5. Holdings domiciled outside of U.S. must actively trade on NYSE or NASDAQ. 6. Less than two times Russell 2500 Growth sector weight, with 40% maximum exposure to any sector. 7. Less than 20% of portfolio in stocks larger than the largest company in the Russell 2500 Growth. Non-Participation in Wrap Fee Programs SCA does not sponsor any wrap fee programs. In traditional (non-wrap fee) management programs, advisory services are provided for a fee but transaction services are billed separately on a per-transaction basis. In wrap-fee programs, advisory services and transaction services are provided for one fee. Specialization SCA specializes in managing equity accounts for clients with assets of $1 million or more through the use of a model portfolio for the Small Cap Growth and SMid Cap Growth strategies. Limits Advice to Certain Types of Investments. SCA limits its investment advice to the following types of investments:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issues traded on domestic exchanges Advisory Services Tailored to Individual Needs of Clients For the Summit Creek Portfolio Management Services, SCA will use discretion to supervise and direct the investments of the client’s assets in accordance with the written investment objectives, policies, and reasonable restrictions that the client has furnished to SCA and according to any revisions thereto provided by the client. If stated within the Investment Management Agreement, SCA provides each client with an annual Compliance Certification verifying that SCA has structured the client’s portfolio in a manner that is in compliance with the client’s specified investment guidelines on file with SCA. For the Summit Creek Strategist Services, SCA will provide investment recommendations and updates in accordance with the written investment objectives developed by SCA, as well as any reasonable restrictions that the institutional/corporate client has furnished to SCA and according to any revisions thereto provided by the client. If stated within the Investment Management Agreement, SCA provides each institutional/corporate client with an annual Compliance Certification verifying that SCA has provided recommendations and updates for the client that are in compliance with the client’s specified investment guidelines with SCA.