Barnett & Co. Inc.

Barnett & Company Inc. 1300 Broad Street, Suite 303 Chattanooga, TN 37402-4476 (423) 756-0125 www.barnettandcompany.com August 12, 2026 This brochure provides information about the qualifications and business practices of Barnett & Company Inc. If you have any questions about the contents of the brochure, please contact us at 423-756-0125 or info@barnettandcompany.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Barnett & Company is also available on the SEC’s website at www.adviserinfo.sec.gov. Barnett & Company’s CRD number is 105867. Page 1 Barnett & Company Form ADV, Part 2A August 2026  Item 2. Material Changes Investment Advisers are required to prepare a disclosure document (“Brochure”) that describes the firm and its business practices. Pursuant to SEC rules, we are required to update our Brochure at least annually and provide you with a summary of any material changes since the previous amendment which was filed on January 29, 2026. The firm updated the following items: Items 4, 5, 7, 8, 12, 13, 16 and 17: These items were updated to disclose the Griffon Strategies program. Barnett & Company may use the Griffon model strategies both in its direct wealth management business and through sub-advisory arrangements with unaffiliated investment advisers. Barnett & Company may recommend the strategies to new and existing direct clients, including clients with smaller account balances, when the Firm determines a strategy is appropriate. Direct clients are charged under Barnett & Company’s existing wealth and asset management fee schedule. The amendments also describe the sub-advisory structure, division of responsibilities with partner advisers, strategy risks, brokerage and account review practices, investment discretion, and proxy-voting responsibilities. We will deliver a complete copy of our Investment Adviser Brochure upon your request at any time during the year. You may request our Brochure by contacting Barnett & Company at (423) 756-0125 or info@barnettandcompany.com. Additional information about Barnett & Company Inc. is available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Barnett & Company Inc. who are registered as investment adviser representatives. Page 2 Barnett & Company Form ADV, Part 2A August 2026  Item 3. Table of Contents Item 1. Cover Page ................................................................................................................ 1 Item 2. Material Changes ...................................................................................................... 2 Item 3. Table of Contents ...................................................................................................... 3 Item 4. Advisory Business ..................................................................................................... 4 Item 5. Fees and Compensation ............................................................................................ 6 Item 6. Performance Based Fees and Side-By-Side Management ........................................... 8 Item 7. Types of Clients ......................................................................................................... 8 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ..................................... 8 Item 9. Disciplinary Information .......................................................................................... 11 Item 10. Other Financial Industry Activities and Affiliation .................................................. 11 Item 11. Code of Ethics, Participation in Transactions, Personal Trading .............................. 12 Item 12. Brokerage Practices............................................................................................... 12 Item 13. Review of Accounts ............................................................................................... 13 Item 14. Client Referrals and Other Compensation .............................................................. 14 Item 15. Custody ................................................................................................................ 15 Item 16. Investment Discretion ........................................................................................... 15 Item 17. Voting Client Securities ......................................................................................... 16 Item 18. Financial Information ............................................................................................ 16 Page 3 Barnett & Company Form ADV, Part 2A August 2026  Item 4. Advisory Business Barnett & Company was founded in 1983 by Warren M. Barnett, CFA. The principal owner is Warren M. Barnett. The firm has two portfolio managers who offer investment advisory services. Wealth and Asset Management Services Barnett & Company offers ongoing portfolio management services based on the individual goals, objectives, time horizons and risk tolerances of each client. Clients complete an Investment Questionnaire to assist Barnett & Company with building a portfolio that is specific to the client’s financial situation. We recognize that clients may be averse to certain investments, and we will make portfolio adjustments when warranted. Some clients impose unique restrictions in their accounts. Barnett & Company invests client portfolios in publicly traded marketable securities. Equity investments selected for client accounts may include common stock, preferred stock, real estate investment trusts and master limited partnerships. Fixed income securities may include U.S. Treasury notes and bills. Investment company securities, such as exchange-traded funds, mutual funds and business development companies are also used. Other types of investments may be selected for client accounts if such investments meet the specific goals and objectives of the client. Financial Planning and/or Consulting Services We can provide personal financial planning and consulting services that include education, advice and the preparation and delivery of a written financial plan that will include general recommendations to help the client achieve his or her personal financial goals. Our personal financial planning services typically involve three steps: • gathering information from the client and completing a client profile; • developing the advice or plan; and • delivering and presenting the plan. A client may enter into a financial planning engagement with Barnett & Company by signing a financial planning services agreement and, in most cases, agreeing to pay a fee in exchange for those services. The agreement is cancelable at any time by either party for any reason. The financial plan or advice will not include investment advice, analysis, or recommendations regarding specific securities. Upon delivery of a financial plan to a client, the client will review the plan and provide acknowledgement of their receipt of said plan. Acknowledgement of receipt will end the financial planning advisory relationship between the client and us. Page 4 Barnett & Company Form ADV, Part 2A August 2026  Griffon Strategies Separately Managed Account Program Partner Advisers may communicate reasonable account-specific investment restrictions. Barnett & Company will seek to implement restrictions when operationally feasible. Restrictions may cause an account to differ from the applicable model and may affect performance. Barnett & Company generally does not provide financial planning or independently determine the overall suitability of the Program for the Partner Adviser’s underlying client unless separately agreed in writing. Barnett & Company may also recommend and implement the same Griffon model strategies for new and existing clients of Barnett & Company’s direct wealth and asset management business, including clients with smaller account balances. In these direct client relationships, Barnett & Company maintains the advisory relationship, determines whether the selected strategy is appropriate based on the client’s circumstances, and provides ongoing discretionary investment management. These accounts generally follow the applicable Griffon model, subject to reasonable client-specific restrictions and other account considerations. The Program currently includes Value, Growth and Income strategies. The Value Strategy emphasizes companies Barnett & Company believes are undervalued relative to their fundamentals. The Growth Strategy emphasizes companies Barnett & Company believes have durable competitive characteristics and above-average growth prospects. The Income Strategy emphasizes sustainable cash flows, dividends and income-oriented total return. Barnett & Company may add, modify, combine, rename, suspend or discontinue a strategy when it determines that doing so is appropriate. Barnett & Company manages Program assets primarily through standardized model portfolios and is responsible for investment research, security selection, model portfolio construction, trading, rebalancing and ongoing monitoring. Investment decisions generally are made at the model level and implemented across accounts assigned to the applicable strategy, subject to account restrictions, available cash, tax considerations, custodial limitations and other operational factors. The Partner Adviser maintains the primary advisory relationship with its clients and is responsible for determining each client’s investment objectives, risk tolerance, time horizon, liquidity needs, tax considerations and other relevant circumstances. The Partner Adviser selects the Griffon strategy it determines is appropriate for the client and is responsible for determining on an ongoing basis whether the selected strategy remains appropriate. Barnett & Company offers investment management services through the Griffon Strategies Separately Managed Account program (“Griffon Strategies” or the “Program”) to unaffiliated registered investment advisers (“Partner Advisers”). Under the Program, Barnett & Company generally serves as a sub-adviser and provides discretionary investment management services for designated accounts of the Partner Adviser’s clients. Page 5 Barnett & Company Form ADV, Part 2A August 2026  Education Only Retirement Plan Support ‑ Barnett & Company provides education-only services to employer-sponsored retirement plans. These services include general information about plan features, asset-class education, explanations of risk and return concepts, and participant financial wellness programs. We do not provide individualized investment advice, securities recommendations, or model portfolios. We do not select or monitor investment options, and we do not exercise discretionary authority over any plan assets. All investment decisions remain solely with the plan sponsor or another designated plan fiduciary. As of December 31, 2025 Barnett & Company had $142 million in regulatory assets under management, all of which is managed on a discretionary basis. Item 5. Fees and Compensation Wealth and Asset Management Fees Clients pay Barnett & Company a fee based on the value of assets in their account. Fees are charged quarterly in advance based on the value of the account on the last day of the previous quarter. While Barnett & Company intends to charge fees in accordance with the standard fee schedule in place at the time of executing the portfolio management agreement, fees may be subject to negotiation in limited circumstances and may vary from the standard schedules to reflect circumstances that apply to a specific client account. The fee schedule, and any applicable terms and conditions, is stated in the client’s portfolio management agreement. When Barnett & Company recommends a Griffon strategy to a client of its direct wealth and asset management business, the client is charged in accordance with the Wealth and Asset Management Fees described above; no separate Griffon strategy fee is charged. The firm’s current schedule is as follows: First $1 million Next $2 million Next $2 million Next $5 million Over $10 million 1.00% per annum .75% per annum .70% per annum .65% per annum .60% per annum Either party may terminate the portfolio management agreement upon notice to the other party. Upon termination, clients will be refunded all fees paid but unearned as of the date of termination within 30 days of such date. Termination of the agreement will not affect the liabilities or obligations incurred or arising from transactions initiated under the agreement prior to the termination. Page 6 Barnett & Company Form ADV, Part 2A August 2026  Clients may, but are not required to, grant Barnett & Company the authority to debit advisory fees directly from the clients’ accounts. If the client authorizes Barnett & Company to debit fees, notice of such fee is delivered promptly to the client. Clients will receive a statement, usually monthly but no less than quarterly, directly from their account custodian. Barnett & Company urges clients to review the information on the statement for accuracy and compare the information to any reports received directly from Barnett & Company. Please refer to the Custody section of this document for additional disclosures relating to the deduction of advisory fees. The advisory fee covers only the portfolio management and advisory services provided by Barnett & Company and does not include brokerage commissions, mark-ups and mark-downs, exchange fees, dealer spreads, trade away fees, special handling fees, or other costs associated with the purchase and sale of securities, custodian fees, transfer fees, wire fees, interest, taxes, or other account expenses. All fees paid to Barnett & Company for investment advisory services are separate and distinct from the internal fees and expenses charged by mutual funds or exchange- traded funds. The client will be solely responsible, directly or indirectly, for these additional expenses. Barnett & Company does not receive any portion of these additional fees. Refer to the section titled “Brokerage Practices” for additional information. Financial Planning and/or Consulting Fees Financial planning and consulting services can either be charged at an hourly rate of $175, with an estimated initial cost of $1,000 to $1,500, or charged based on the assets that fall within the scope of the financial plan. Typically, these fees will be due upon receipt. Prior to engaging Barnett to provide these services, clients are required to sign an Engagement Letter, which sets forth the terms and conditions of the engagement, including fees. Fees will be discussed and agreed upon between the client and Barnett and will be specifically identified in the Engagement Letter. As a financial planning or consulting client, you are under no obligation to act upon any of our recommendations or effect the transaction(s) through us if you decide to follow the recommendations. Retirement Plan Support Fees For these education-only services, Barnett & Company is compensated directly by the plan sponsor based on the terms of the service agreement. The plan’s recordkeeper facilitates the administrative processing and remittance of our compensation on behalf of the plan sponsor. Griffon Strategies Fees Page 7 Barnett & Company Form ADV, Part 2A August 2026  Unless otherwise agreed in writing, the Partner Adviser is responsible for billing its clients and remitting Barnett & Company’s sub-advisory fee. Barnett & Company generally does not bill the Partner Adviser’s underlying clients directly. The Partner Adviser may charge its client a separate advisory fee in addition to the fee paid to Barnett & Company. As a result, a client participating in the Program may pay higher aggregate advisory fees than if the Partner Adviser managed the assets without engaging Barnett & Company. Clients may also incur brokerage, custodial, fund- level and other expenses separate from advisory and sub-advisory fees. Under Barnett & Company’s standard Griffon Strategies sub-advisory arrangement, Barnett & Company receives an annual fee of 0.40% of assets managed through the Program, calculated quarterly in arrears based on the average daily market value of the applicable assets. Different sub-advisory fee arrangements may be negotiated based on the nature and scope of the relationship. Item 6. Performance Based Fees and Side-By-Side Management Barnett & Company does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7. Types of Clients Barnett & Company generally provides investment advice to individuals, high-net-worth individuals, charitable organizations and registered investment advisers. Through Griffon Strategies, Barnett & Company may provide sub-advisory investment management services to unaffiliated registered investment advisers for designated accounts of their clients. Barnett & Company may also recommend Griffon strategies to new and existing direct wealth management clients, including clients with account balances below the Firm’s typical $500,000 minimum. The Firm may waive or reduce its stated account minimum based on the nature of the relationship and the strategy to be used. Different minimums or eligibility requirements may apply to sub- advisory relationships pursuant to the applicable agreement. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Barnett & Company uses fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, the analysis of management and the review of competitive advantages. Through a process of screening large numbers of stocks using public information and proprietary databases available by subscription, Barnett & Company looks for companies with both positive prospects and low current valuation relative to those prospects. We then evaluate the financial health of companies using a number of additional screening tools. Finally, we perform qualitative Page 8 Barnett & Company Form ADV, Part 2A August 2026  analysis by perusing the company’s SEC filings and testing for criteria that would have an adverse effect on stock ownership. For appreciation-oriented accounts, the end result of these efforts is a collection of stocks that we believe merit investment consideration. When several stocks in a given industry make the list, we narrow them down to the one or two companies in the group that we feel have the best prospects for appreciation. Our selling methodology is equally quantitative. When a stock sells for more than twice its long- term earnings growth, we consider it a candidate for sale. Other factors that may cause the selling of a stock are a revision of earnings, material deviation from reported earnings, or issues related to the reliability of accounting or forecasting data. Barnett & Company remains equally flexible in deciding on the selling point of a stock. The goal when buying a stock for appreciation is to see a substantial increase in its value over a period of three to five years. Even if this objective is not realized, the goal itself tends to focus thinking on long term potential rather than on short term trading. Such focus is especially helpful in situations where long-term capital gains are desired. In investing for both current income and appreciation, Barnett & Company employs a more modest goal for price changes since a material portion of return will come from cash flow. Barnett & Company generally shies away from investments that cannot be priced by the marketplace. However, in some cases, a low volume of trading in a particular security may cause the market to misprice the security. The lack of readily available pricing limits our ability to sell an investment, if need be. Lack of access to information about sales can jeopardize the objectivity of the valuation of a potential investment. Investing in securities involves risk of loss that clients should be prepared to bear. Barnett & Company uses its best judgment and good faith efforts in providing advisory services to clients. Barnett & Company cannot warrant or guarantee any particular level of account performance, or that an account will be profitable over time. Not every investment decision or recommendation made by Barnett & Company will be profitable. Investments in securities are subject to various market, currency, inflation, economic, political, and business risks. Barnett & Company attempts to minimize these risks by constructing diversified portfolios appropriate for the specific risk parameters of the investment strategy. • Market Risk: Investments are subject to risk, including the possibility of a loss of principal. Fluctuations in the value of an investment may be caused by external factors independent of an investment’s particular underlying circumstances. Page 9 Barnett & Company Form ADV, Part 2A August 2026  • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Inflation Risk: High inflation may adversely affect future purchasing power. • Currency Risk: Foreign investments are subject to fluctuations in the value of the dollar versus the local currency where the investment is made. • Reinvestment Risk: Reinvestment risk occurs when proceeds from an investment may be reinvested at lower prevailing rates. • Business Risk: Business risks are associated with a particular industry or a particular company within an industry. • Liquidity Risk: Liquidity risk occurs when there is a possibility an investment cannot be readily converted to cash. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Barnett & Company may, at times, choose to invest a portion of client assets in master limited partnerships (“MLPs”). MLPs are traded like equity securities on a national exchange; however, risks and other factors associated with investing in MLP are significantly different from investing in common stocks or bonds. While we intend to select MLPs with sufficient trading volume, MLPs are sometimes thinly traded and may not be liquid or marketable once purchased. MLPs primarily invest in companies that produce and distribute energy and fuels, such as pipelines and other related infrastructure. These companies are affected by fluctuations in supply and demand; interest rates; special risk of constructing and operating facilities or installations; lack of control over pricing, merger and acquisition activity; and federal, state and local regulation. Such fluctuations may, among other things, increase the costs of doing business and limit the potential for growth. MLPs themselves do not pay U.S. federal income tax at the partnership level. Each investor in an MLP will be issued a K-1 annually showing the allocation of income, gains, losses, deductions and expenses. Changes in tax law could adversely affect the amount of funds available for distribution by the partnership. Furthermore, the partnership could invest in companies that could subject a tax-exempt investor to unrelated business taxable income (“UBTI”). Page 10 Barnett & Company Form ADV, Part 2A August 2026  Griffon Strategies There can be no assurance that any Griffon strategy will achieve its investment objective. Investing in securities involves risk of loss, including possible loss of principal. Accounts assigned to the same model may experience different results because of client restrictions, cash flows, tax considerations, timing, transaction costs, custodial limitations or other operational factors. Strategy-specific risks also apply. Growth-oriented securities may be more sensitive to changes in expected growth or valuation; securities believed to be undervalued may remain undervalued or decline further; and dividend-paying securities may reduce or eliminate dividends. Concentration in particular companies, industries, sectors or investment factors may increase volatility or losses. ETFs and other pooled vehicles are subject to the risks and expenses of their underlying investments. In addition to the risks described above, Griffon Strategies is subject to model portfolio risk. Accounts generally follow a common model rather than being individually constructed for each client, and a model may not reflect every client-specific circumstance. For direct Barnett & Company clients, Barnett & Company is responsible for determining whether the selected strategy is appropriate. For accounts managed through a sub-advisory arrangement, the Partner Adviser is responsible for selecting the strategy and determining whether it remains appropriate for its client. Griffon Strategies uses the Firm’s fundamental investment process within standardized model portfolios. Depending on the strategy, Barnett & Company may invest in U.S.-listed common stocks and ADRs and may selectively use ETFs, closed-end funds, REITs and listed infrastructure securities when consistent with the strategy. The strategies are generally long-only. Barnett & Company establishes holdings, target weights and risk parameters at the model level and generally implements investment decisions across accounts assigned to the same strategy. Item 9. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Barnett & Company or its management. The firm is not presently subject to any legal or disciplinary actions. Item 10. Other Financial Industry Activities and Affiliation Barnett & Company has no other financial industry activities or affiliations to report. Page 11 Barnett & Company Form ADV, Part 2A August 2026  Item 11. Code of Ethics, Participation in Transactions, Personal Trading Barnett & Company has adopted a Code of Ethics that sets forth a standard of conduct required by Barnett & Company’s supervised persons and requires compliance with applicable securities laws, including the Insider Trading and Securities Fraud Enforcement Act of 1988. An investment adviser’s Code of Ethics requires certain employees (Access Persons) to report their personal securities holdings within ten days of being hired and annually thereafter and are required to report securities transactions within thirty days of the end of each calendar quarter. The Chief Compliance Officer or other designated person reviews employees’ personal investment activity to ensure employee trading activity does not conflict with advice provided to clients. A complete copy of Barnett & Company’s Code of Ethics is available to any client or prospective client upon request. Barnett & Company has adopted policies and procedures imposing certain conditions and restrictions on transactions for the accounts of Barnett & Company’s employees. Barnett & Company employees are permitted to make investments in securities that are also held in client portfolios, which may raise potential conflicts of interest when such persons trade in a security that is owned or considered for purchase or sale by a client. Barnett & Company’s Code of Ethics requires employees to conduct their personal trading in a manner that does not create a conflict of interest with a client, or otherwise take unfair advantage of the client relationship. Employees are required to obtain approval from the Chief Compliance Officer, or other designee, prior to executing trades for their own account in any private placement or initial public offering. Barnett & Company employees are prohibited from taking action for personal benefit rather than for a client’s benefit, and from using their knowledge of client transactions for personal profit. Item 12. Brokerage Practices Obtaining best execution is an important aspect of the advisory services we offer our clients. Best execution can be described as seeking the most favorable terms for completing transactions considering all relevant circumstances at the time. We take a best practices approach to trading principles to ensure transactions are executed in a manner that is most beneficial to our clients. For Barnett & Company’s direct wealth and asset management clients, Barnett & Company requires clients to utilize the custodial services of Charles Schwab & Co., Inc. (“Schwab”), through its institutional adviser platform program in which Barnett & Company participates. For Griffon Strategies accounts, the qualified custodian is generally selected by the Partner Adviser and must provide Barnett & Company with the trading authority and operational access necessary to manage the account. Barnett & Company typically directs trades for its direct wealth management clients to be executed, cleared and settled through the Schwab platform when such direction satisfies its internal best execution guidelines. The reason for this preference includes, but is not limited to: discounted commission rates; dedicated trading and/or client service personnel; availability of no load, no transaction fee, load-waived and institutional class mutual Page 12 Barnett & Company Form ADV, Part 2A August 2026  funds; access to electronic and/or block trading; daily transaction download and reconciliation files; discounts on compliance, marketing, research, technology and practice management products and services provided by third party vendors; and familiarity of our staff with their operational procedures. While these benefits create a potential conflict of interest on behalf of Barnett & Company, there is no direct link between Barnett & Company’s participation in the platform and the advice it gives to clients and are not dependent on the amount of brokerage transactions directed to the custodian. ‑ While Barnett & Company generally executes client trades through Schwab, the firm may use other broker dealers in circumstances where it reasonably believes doing so would result in improved execution quality consistent with its duty of best execution. When selecting broker- dealers to execute client transactions, Barnett & Company evaluates the services provided by broker-dealers and may consider, among other things: Integrity and reputation; • Reliability, efficiency and overall quality of service provided; • Transaction costs; • Liquidity provided; • Financial condition; • • Error resolution. Barnett & Company generally aggregates client purchase and sale orders of securities with those of other clients where, in Barnett & Company’s judgment, such aggregation is reasonably likely to result in an overall economic benefit to clients participating in the trade. Clients participating in an aggregated order will receive the average price of all transactions executed on a pro rata basis. If an order is partially filled, shares will be allocated pro rata based on the client’s initial participation in the transaction. To the extent that the limited availability of a security would result in a de minimis allocation, Barnett & Company may, based on the facts and circumstances, exclude one or more accounts from participating in the order and/or select an alternative allocation method provided that such method is fair and equitable to all client accounts over time. For Griffon Strategies, Barnett & Company generally implements model changes across participating accounts in a manner intended to be fair and equitable. Account restrictions, available cash, tax considerations, custodial or platform limitations and other practical factors may result in differences in timing, execution prices, holdings or performance among accounts assigned to the same model. Item 13. Review of Accounts Page 13 Barnett & Company Form ADV, Part 2A August 2026  Investment Advisor Representatives review client accounts on an ongoing basis, and no less frequently than quarterly. Reviews may be triggered by material market, economic or political events or by changes in the client’s financial situations (such as retirement, termination of employment, physical move or inheritance.) We provide each client with a quarterly written report detailing the client’s account positions and performance. Clients will also receive an account statement from their custodian, which includes an inventory of holdings and a detailed listing of all transactions. For Griffon Strategies, Barnett & Company reviews model portfolios and underlying holdings on an ongoing basis. The Partner Adviser remains responsible for reviewing the underlying client’s circumstances and determining whether the selected model remains appropriate. Barnett & Company may provide model updates, commentary and performance materials to the Partner Adviser; client reporting is generally provided by the Partner Adviser or custodian unless otherwise agreed in writing. Item 14. Client Referrals and Other Compensation Barnett & Company receives certain benefits from Schwab for providing advice to clients in connection with the Schwab Advisor Services program. This type of relationship poses a conflict of interest and is further disclosed in response to Item 12, above. Referral Arrangements Barnett & Company may from time to time enter into client referral agreements with unaffiliated third-party promoters whereas the promoters may refer prospective clients whose investment goals and objectives are compatible with Barnett & Company's investment approach. Barnett & Company may compensate the promoter through direct or indirect compensation in accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements. Prospective clients will be provided with disclosures at the time of the solicitation that state whether the promoter is a current client of the firm; whether the promoter will receive any cash or non-cash compensation for the referral; and that the receipt of compensation for a referral creates a conflict of interest. In addition, each prospective client will be provided with a copy of a written disclosure statement disclosing the terms and conditions of the arrangement between Barnett & Company and the promoter, including the compensation the promoter will receive from Barnett & Company and any material conflicts of interest on the part of the promoter as a result of the referral arrangement. Barnett currently has no current referral agreements in place. However, the firm maintains a legacy referral agreement with Charles Schwab & Co, Inc. and continues to pay fees on previously referred relationships. Page 14 Barnett & Company Form ADV, Part 2A August 2026  Item 15. Custody Barnett & Company is deemed to have custody of client funds as the result of debiting investment advisory fees from client accounts. Debiting fees is done pursuant to authorization provided by each client and approval of the custodian. Usually monthly, but no less than quarterly, clients receive account statements directly from the custodian of their account. Custodial statements include account holdings, market values and any activity that occurred during the period, including the deduction of investment advisory fees. Barnett & Company also sends periodic reports to clients. Clients are urged to compare information contained in reports provided by Barnett & Company with the account statements received directly from the account custodian. Differences in portfolio value may occur due to various factors, including but not limited to: (1) unsettled trades; (2) accrued income; (3) pricing of securities; and (4) dividends earned but not received. Barnett & Company is also deemed to have custody of client funds or securities in cases where the client has granted third-party funds transfer authority. Pursuant to the SEC no-action letter dated February 21, 2017, Barnett & Company is not subject to independent verification under Rule 206(4)-2(a)(4) since the firm maintains the seven conditions enumerated in the SEC guidance. Item 16. Investment Discretion Barnett & Company offers discretionary investment services. For our discretionary accounts, clients enter into a written agreement with Barnett & Company granting the firm the authority to supervise and direct, on an ongoing basis, investments in accordance with the client’s investment objective and guidelines. Clients will also execute any and all documents required by the Custodian so as to authorize and enable Barnett & Company, in its sole discretion, without prior consultation with or ratification by you, to purchase, sell or exchange securities in and for your account. Clients may impose restrictions on investing in certain securities, types of securities, or with regard to investment strategies. A client should set forth these restrictions, in writing, after a discussion with the portfolio manager. Under Griffon Strategies, the Partner Adviser delegates discretionary trading authority to Barnett & Company for designated client assets pursuant to a written sub-advisory agreement and appropriate custodial authorization. This authority permits Barnett & Company to buy, sell and rebalance securities without prior approval for each transaction, subject to the selected strategy and written investment restrictions. Unless separately authorized in writing, Barnett & Company’s authority is limited to investment management and trading and does not permit Barnett & Company to withdraw client assets, change account registration or beneficiary designations, deduct advisory fees, or otherwise exercise control over client funds or securities other than as necessary for trade settlement. The Partner Adviser is responsible for obtaining any client consent necessary to appoint Barnett & Company as sub-adviser. Page 15 Barnett & Company Form ADV, Part 2A August 2026  Item 17. Voting Client Securities Barnett & Company may choose to, but is not required to, vote proxies on a client’s behalf. Clients that retain proxy-voting responsibilities will receive all issuer communications directly from their custodian. Barnett & Company has engaged the services of a third party proxy vendor to assist with proxy administration and to vote on behalf of Barnett & Company clients. Barnett & Company generally votes proxies in accordance with the recommendations made by the management of the companies in which the clients are invested. This approach is based on the belief that management is best positioned to make decisions that enhance the long-term value of the investment. While Barnett typically aligns its votes with management, it reserves the right to deviate from management recommendations when it deems it necessary to protect the best interests of its clients. Factors such as conflicts of interest, corporate governance issues, or potential impacts on shareholder value may be considered in such cases. In situations where a conflict of interest arises between Barnett & Company and a client with respect to a particular security or a specific issue on the proxy ballot, the conflict of interest will be disclosed to the client, and the client may direct Barnett & Company how to cast the vote on their behalf. Where Barnett & Company is authorized to vote client proxies, the firm will evaluate securities action matters and determine whether it is appropriate to file proofs of claim on behalf of class clients. In cases where Barnett determines that filing a claim is warranted, the firm will prepare and submit the proof of claim documentation. Barnett & Company periodically monitors and reviews its proxy voting policies to ensure their continued effectiveness. Clients can obtain Barnett & Company’s Proxy Voting Policies and Procedures and/or a report summarizing each corporate issue and corresponding proxy vote by contacting Barnett & Company at info@barnettandcompany.com. For Griffon Strategies accounts, proxy voting authority generally remains with the Partner Adviser unless Barnett & Company expressly accepts that authority in writing. Unless otherwise agreed in writing, the Partner Adviser is also responsible for regulatory filings applicable to its clients or accounts and for corporate actions, tender offers and class action matters. Item 18. Financial Information Registered investment advisers are required to provide certain financial information or disclosures about their financial condition. Barnett & Company has been funding its operations since 2015, in part, by deferring dividends on Series A Preferred shares it had previously issued to clients and other investors. During this period, Barnett & Company redeemed Series C Preferred shares owned by its president, Warren Barnett. Page 16 Barnett & Company Form ADV, Part 2A August 2026