Firm Description This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications, business practices and the advisory services provided by Pine Haven Investment Counsel, Inc. (“Pine Haven or the “Firm,” “we,” “us, ours,”). We are a federally Registered Investment Adviser with the U.S. Securities and Exchange Commission (“SEC”). We were founded in 1999 and are owned and operated by Paige Johnson Roth, President, Chief Executive Officer and Chief Compliance Officer. Types of Advisory Services Investment Advisory Services We provide investment supervisory services. To do this we evaluate our client’s financial, family, and investment situation and discuss goals and objectives. Using this information, we develop a plan, which includes investment strategy and asset allocation. The investments selected are based upon clients’ unique circumstances. In most cases, discretionary authority is given to us to enact the plan, buy and sell individual investments and continuously supervise investments in your accounts. We stress a long-term total return approach. Accounts are diversified and holdings are intended to be held through market cycles supporting clients’ short and long-term goals. Investments are made in the spirit of investing in the underlying companies and not speculating on current market trends or sentiment. To provide diversification supportive of each client’s unique situation, we may invest in stocks of large United States companies, utilize mutual funds, exchange traded funds (ETF’s), real estate investment trusts, business development corporations, sub-advisers (other investment advisers), bonds, cash, and cash equivalents. We may also provide advice about any type of legacy position or investment otherwise held in client portfolios. Financial Planning/Investment Counsel We provide financial planning and counsel as part of our services to our clients. In most cases this includes retirement, tax, charitable, and estate planning. We do not prepare taxes. We generally do not provide standalone financial planning services. Occasionally, we do have short term projects for specific financial planning issues. We believe that the continuous monitoring of investments is an important part of our services. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Tailored Relationships We tailor our investment advisory services to the individual needs of the client. Our clients may choose to impose restrictions on the investments in their account. We may accept any limitation or restriction to discretionary authority on the account provided it is reasonable and does not hamper prudent risk management. All limitations and restrictions placed on accounts must be presented to us in writing. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. We do not sponsor, manage, or participate in a Wrap Fee Program. Client Assets As of December 31, 2023, we managed $152,367,158. Our discretionary assets were $140,676,212 and our non-discretionary assets were $11,690,946.