Description of Services and Fees Bristlecone Value Partners is a registered investment adviser in Los Angeles, California. We are organized as a limited liability company under the laws of the State of Delaware. We have been providing investment advisory services since 2004. The Nouzille Family Trust (U/A, dated 8/24/2004), the Fleer Miler Family Trust (U/A dated 9/9/2008), and Josh Graybill are our principal owners. We are a fee-only independent, employee-owned asset management firm providing asset allocation, investment advisory, and sub-advisory services to individuals, families, and institutions. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our services to your needs. As used in this brochure, the words "we", "our" and "us" refer to Bristlecone Value Partners and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person or Investment Adviser Representative throughout this brochure. As used in this brochure, our Associated Persons or Investment Adviser Representatives are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Investment Supervisory Services We offer discretionary and, occasionally, non-discretionary supervisory services tailored to meet our clients' needs and investment objectives. Our investment supervisory services are designed to address the following areas of the investment process: objective setting, asset allocation, selection of securities, mutual funds and other pooled investment vehicles, and performance monitoring. If you retain our firm for Investment Supervisory Services, we will meet with you in person or by telephone to determine your investment objectives, financial constraints, willingness to accept trade- offs between risks and returns, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to assist you in allocating assets among various asset classes. Once we construct an investment portfolio for you, we will monitor your portfolio's performance continuously and will rebalance the portfolio as required by changes in market conditions and your financial circumstances. Separately Managed Equity Accounts We provide discretionary investment advice and management through Separately Managed Equity Accounts. Separately Managed Accounts (SMAs) are professionally managed portfolios of securities. The main advantage of SMAs over mutual funds and other pooled investment vehicles is your direct ownership of securities in the portfolio. This permits customization and provides an individual cost basis for income tax purposes, giving you more control of the tax consequences of the timing of purchases and realized profit or loss. Our firm offers the Large Cap Value strategy through SMAs. Portfolios are concentrated and primarily invested in shares of 30 to 40 mid to large cap companies (typically greater than $3 billion in market capitalization). Our Large Cap Value strategy's long-term focus and low turnover are particularly well- suited for high-net-worth individuals, foundations, and endowments. A minimum allocation of $100,000 in investable assets is typically required for this service. When appropriate, we will decide the percentage of your portfolio allocated to our Large Cap Value Separately Managed Equity Accounts. To limit potential conflicts of interest associated with allocating a greater proportion of your portfolio to our Large Cap Value Accounts than your investment objectives and financial situation would warrant, we have intentionally structured our fee schedule for advisory services below to be the same, irrespective of the underlying selection of investment options. We also believe that allocating a portion to our Large Cap Value Accounts or buying securities without using the services of third-party asset managers has the potential to benefit our clients as it reduces the overall total costs associated with our services. We require you to grant our firm discretionary authority to manage your account. Only in very limited cases and only for clients who have most of their assets under discretionary authority with our firm will we consider accepting an account on a non-discretionary basis. The discretionary authorization will allow our firm to determine the specific securities and the amount to be purchased or sold for your account, the broker/dealer to be used, and the commission rate to be paid without your approval before each transaction. Discretionary authority is typically granted by the Investment Management Agreement you sign with our firm, a limited power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, restricting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval before executing any transactions on behalf of your account. Our fee for advisory services is based on a percentage of the assets we manage on your behalf and is outlined in the following fee schedule: Assets Under Management Annual Fee1 Up to $500,000 1.00% Next $500,000 0.85% Next $500,000 0.70% Next $1,000,000 0.50% Next $2,500,000 0.30% Assets over $5 million 0.15% Our annual advisory fee is billed and payable quarterly in advance based on the value of your account on the last day of the previous quarter. If the Investment Management Agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro-rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. No adjustment will be made when

withdrawals or deposits are made during a quarter (mid- billing cycle). Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other related accounts. Combining account values will increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We typically deduct our advisory fee directly from your account(s) through the qualified custodian holding your funds and securities. In certain instances, when assets are held with custodians other than our primary relationships ("held-away") or due to tax, compliance, operational, or other considerations, we may deduct the fee assessed on one account from a different account. We will deduct our advisory fee only when you have given our firm written authorization to pay directly from your account(s). Further, we will deliver a quarterly billing statement showing you all disbursements from your account. You should review all statements for accuracy. 1 Accounts opened before the effective date of this fee schedule may pay more or less for the same advisory services. Fees are subject to change at our discretion with advance notification. Charitable organizations have a separate, discounted fee schedule. Lower fees for comparable advisory services may be available from other sources. You may terminate the Investment Management Agreement with no penalty within five days of the date of acceptance. After five days, you or our firm may terminate the Investment Management Agreement upon 30 days written notice to the other party. You will incur a pro-rata charge for services rendered before the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. 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. How we make money creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests 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 to ensure we advise 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 a retirement account to an account that we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Management Services to Pooled Investment Vehicle We are the General Partner and investment adviser to Bristlecone Microcap Fund, LP (the "Fund"), an unregistered investment company organized as a limited partnership. The Fund primarily invests in publicly traded microcap companies with market capitalizations below the average market cap of the Russell Microcap index, with limited or no institutional research coverage, and low trading liquidity. The Fund is offered only to investors meeting certain sophistication and financial requirements and only by private placement memorandum and other offering documents. We receive a performance-based fee as General Partner and investment adviser to the Fund. The performance-based fee is an incentive allocation equal to 20% of the net profit allocated to each limited partner during each calendar year in excess of a rate of return equal to 6% of each partner's beginning capital account balance for such year, subject to a high-water mark. Investors and prospective investors should refer to the offering documents for the Fund for a complete description of the risks, investment objectives and strategies, fees, and other relevant information about investments. Types of Investments We primarily offer advice on equity and preferred securities, warrants, corporate debt securities, commercial paper, municipal securities, mutual funds, exchange-traded funds, U.S. Government securities, options contracts on securities, and interest in partnerships investing in real estate. Additionally, we may advise you on other investments that we deem appropriate based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular types of securities. You must provide these restrictions to our firm in writing. Assets Under Management As of December 31, 2023, we provide continuous management services for $155,000,000 in client assets on a discretionary basis, and $3,000,000 in client assets on a non-discretionary basis.