Description of Services and Fees Great Northern Asset Management, Inc. d/b/a Lyons Investment Management is a registered investment adviser based in Winter Park, Florida. We are organized as a corporation under the laws of the State of Minnesota. We also conduct business under the name Great Northern Capital. We have been providing investment advisory services since 1994 and under new ownership since December 2012. GNAM Acquisition Corp. is our principal owner. GNAM Acquisition Corp. is owned by Mark Zavanelli and Alexander Read. The following paragraphs describe our services and fees. As used in this brochure, the words "we", "our", "us" and "Adviser" refer to Great Northern Asset Management, Inc. d/b/a Lyons Investment Management ("Great Northern") and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services Lyons Investment Management provides discretionary portfolio management services for separate individual and institutional accounts. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will help you open a brokerage or custodial account in your name. Then your assets will be invested in one or more strategies which we will work with you to choose. Once your assets are invested, we will monitor the portfolio(s) on an ongoing basis and your account will be rebalanced as required by changes in market conditions and the particular strategy.
We require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the sub-advisor to be used, if any, specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm or trading authorization forms.
In most circumstances we will invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. We generally do not accept client restrictions on the specific securities or the types of securities that may be held in their account, however exceptions may be made on a case-by-case basis. In such cases, this may prevent a client from investing in certain models that are managed by our firm. Since our investment recommendations are based on each client's specific financial situation, investment advice regarding the same security or investment strategy may differ from client to client.
Advisory Services to Retirement Plans We also offer discretionary portfolio management services to employee benefit plans ("Plan"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan are described above, and in the service agreement that you have previously

signed with our firm. Our compensation for these services is described below, under the Fees and Compensation section, and are also in the service agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan. If we 4 receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. Wrap Fee Programs We are a portfolio manager of a wrap fee program sponsored and administered by Morgan Stanley Wealth Management ("MS"). We manage wrap fee accounts on a discretionary basis through Morgan Stanley Smith Barney LLC's platform. Wrap fee accounts are typically more appropriate for active accounts and are managed accordingly. If you participate in this wrap fee program, you will receive a separate Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1) from MS explaining the program and costs associated with the program. You should also review this Part 2A thoroughly to evaluate any differences between our portfolio management services offered through MS's Wrap Fee Program versus the services we offer on a non-wrap basis.
Types of Investments We primarily invest in domestic and foreign equity securities, money market funds, exchange traded funds ("ETFs") and warrants and rights when they are distributed by the equity securities that are exchange-listed or traded over-the-counter. On occasion some of client assets may be invested in foreign currencies.
Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from an ERISA account to an account that we manage or provide investment advice, because the assets increase our assets under management and our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
5 Assets Under Management As of December 31, 2023, we provide continuous management services for $61,637,222 in client assets on a discretionary basis, and $0 in client assets on a non-discretionary basis.