Item 5 – Additional Compensation ........................................................................................... 21 Item 6 – Supervision ................................................................................................................. 21 Item 7 – Requirements for State-Registered Advisers – Legal and Financial Disclosure ........ 21 Palisade Investments, LLC is an investment Adviser registered with United States Securities and Exchange Commission and is a Limited Liability company formed under the laws of the State of Nevada. Palisade Investments, LLC and its predecessor firms Palisade Investments and Everest Capital Management, has been in business since June of 1998 and is owned 100% by Robin DeSota. The business was first registered as Everest Capital Management in 1998. The name changed in 2001 to Palisade Investments. A misfiling of registration in 2003 makes the registration appear to be started in 2004 – even though the business started in 1998. Palisade Investments specializes in retirement plans and wealth management. Pension Consulting - Palisade Investments will provide the Client with investment Advisory services that may include: I. Meeting with plan sponsor to determine (1) current investment categories and options (2) permitted and restricted investment categories and (3) appropriate number of investment options II. Developing an Investment Policy Statement (IPS) III. Assistance with the selection of investment options in each selected investment category IV. Developing strategic portfolios to be used as guidelines by participants in participant directed retirement plans V. Providing quarterly reports detailing the performance of each client’s investment options as they are measured against criteria within the Investment Policy Statement VI. At least annually, an adviser representative will be available to meet with the investment committee to review performance information and to determine if there have been any material changes to the client’s situation VII. Providing one-on-one Advisory services to eligible participants in the retirement plan Financial Planning Services – When offered and/or agreed upon, Palisade Investments, LLC provides Advisory services in the form of financial planning services. Financial planning services do not involve the active management of client accounts, but instead focuses on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax considerations (not tax advice), asset allocation, risk management, retirement planning, and other areas. The

role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Asset Management Services - Palisade Investments, LLC provides Advisory services in the form of Asset Management Services. Asset Management Services involve providing clients with continuous and on-going supervision over client accounts. This means that Palisade Investments, LLC will continuously monitor a client’s account and make trades in client accounts when necessary and permitted. Limits Advice to Certain Types of Investments. Palisade Investments, LLC provides investment advice on the following types of investments.
• Mutual Funds. Palisade Investments, LLC does not get paid commissions or from funds directly
• Exchange-listed securities (i.e. stocks)
• Securities traded over-the-counter (i.e. stocks)
• Exchange Traded Notes (ETNs)
• Fixed income securities (i.e. bonds)
• Closed-End Funds and Exchange Traded Funds (ETFs)
• Foreign Issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance (Advisory only – not paid commissions from insurance companies)
• Variable annuities (Advisory only – not paid commissions from insurance companies)
• United States government securities
• Options contracts on securities and commodities
• Interests in partnerships investing in real estate, oil and gas interests Palisade Investments, LLC does not provide advice on foreign issues, hedge funds and other types of private (i.e. non-registered) securities. When providing Asset Management Services, the firm will typically construct each client’s account holdings using mutual funds or ETFs to build diversified portfolios. It is not Palisade Investments, LLC’s typical investment strategy to attempt to time the market but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations like: low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Palisade Investments, LLC’s services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and/or questionnaires to determine the client’s investment objectives and suitability information. Client Assets Managed by Palisade Investments, LLC The amount of clients’ assets managed by Palisade Investments, LLC totaled $464,596,426 as of January 1st 2024 with $151,662,566 managed on a discretionary basis and $312,933,860 managed on a non-discretionary basis.