Burnham & Company LLC

PART 2A OF FORM ADV-BROCHURE BURNHAM & COMPANY LLC 4930 Cascade Rd SE Suite B Grand Rapids, Michigan 49546 (616) 430-5105 June 10, 2026 This brochure provides information about the qualifications and business practices of Burnham & Company. If you have any questions about the contents of this brochure, please contact us at (616) 430-5105. The United States Securities and Exchange Commission (“SEC”) has not ap- proved or verified the information in this brochure, nor has any state securities authority. Registration of an adviser does not imply any level of skill or training. Additional information about Burnham & Company is available on the SEC’s website at www.adviserinfo.sec.gov. Burnham and Company LLC Page i ADV Part 2A – 6/10/26  ITEM 2: SUMMARY OF MATERIAL CHANGES Pursuant to the amended State Rules, we will provide you with a summary of material changes detailing any material changes that we make to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We will further provide other ongoing disclosure information about material changes as necessary. We do not have any Material Changes to report since the last annual update to this firm brochure, which was on March 5, 2025. Our current Brochure and supplements may be obtained, free of charge, by contacting us at (616) 430-5105 Burnham and Company LLC Page ii ADV Part 2A – 6/10/26  ITEM 3: TABLE OF CONTENTS Page ITEM 1: COVER PAGE.................................................................................................................. i ITEM 2: SUMMARY OF MATERIAL CHANGES ..................................................................... ii ITEM 3: TABLE OF CONTENTS ................................................................................................ iii ITEM 4: ADVISORY BUSINESS ................................................................................................. 1 ITEM 5: FEES AND COMPENSATION ...................................................................................... 2 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................. 4 ITEM 7: TYPES OF CLIENTS ...................................................................................................... 5 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .. 5 ITEM 9: DISCIPLINARY INFORMATION ................................................................................. 9 ITEM 10 : OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS.................. 9 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ........................................................................ 9 ITEM 12 : BROKERAGE PRACTICES ...................................................................................... 10 ITEM 13: REVIEW OF ACCOUNTS ......................................................................................... 13 ITEM 14 : CLIENT REFERRALS AND OTHER COMPENSATION ....................................... 13 ITEM 15 : CUSTODY................................................................................................................... 13 ITEM 16 : INVESTMENT DISCRETION ................................................................................... 14 ITEM 17 : VOTING CLIENT SECURITIES ............................................................................... 14 ITEM 18: FINANCIAL INFORMATION ................................................................................... 14 Burnham and Company LLC Page iii ADV Part 2A – 6/10/26  ITEM 4: ADVISSORY BUSINESS Introduction In this brochure, references to “we,” “us,” “our,” or “our firm” refer to Burnham & Company LLC. Individuals who serve as our directors, officers, and employees are referred to as our “representa- tives.” Our firm’s clients and prospective clients are referred to as “you,” “your” or “our clients.” This brochure contains important information. We encourage you to read it carefully and to ask questions if there is any information that you do not understand. Our Owners and Principals Burnham & Company LLC is a Michigan limited liability company founded in March 2022 by principal owner, Bob Tsironis. Our representatives have substantial business experience and edu- cation in providing investment advice and investment management services for investors, as sum- marized in supplemental brochures that accompany this firm brochure. Advisory Services We primarily provide investment management services. We will work with you to define your investment goals, risk tolerance, income needs, and your service expectations. We also review, and can discuss with you, the investment criteria, investment and financial research, and other parameters that we use to select investment securities for your account. Once we have agreed upon your investment goals, we will purchase and sell securities for your benefit and risk. While we manage most of our individual clients’ accounts based on similar investment strategies suitable for similar investment objectives, we will take your personal financial circumstances into account in formulating our advice and investment decisions. Based upon the information you pro- vide, we will consider many factors such as your income and expenses, assets and other financial resources, financial or special needs, investment goals, anticipated investment time horizon, and other personal financial circumstances. Clients may impose restrictions on investing in certain se- curities, types of securities or sectors of securities. If you have investments held in other accounts not under our management, we will take those investments into consideration if you tell us about them. In managing your account, we will take income tax planning into consideration if you pro- vide us with your historical, current, and anticipated tax-related information. If you desire, we will coordinate our investment decision-making with your tax accountant or preparer. We rely upon you to keep us up to date about changes in your personal circumstances. Our investment management agreement contains your authorization for us to manage your ac- count on a discretionary basis. It also contains important terms and conditions governing our ser- vices, our fees, and our obligations to you. Burnham and Company LLC Page 1 ADV Part 2A – 6/10/26  Retirement Plan Consulting For retirement plan accounts, we can provide any of the following ERISA non-fiduciary services: Education Services to Plan Committee; Participant Education Services; Plan Research Support or Participant Advice. When requested by the client, we will provide any of the following ERISA non-discretionary fiduciary services (ERISA Section 3(21)): create an Investment Policy State- ment; provide Investment Recommendations & Performance Monitoring; or Selection of Qualified Default Investment Alternative. Please note that our ERISA fiduciary services are limited to ERISA Section 3(21) and we do not provide ERISA Section 3(38) fiduciary services. Assets Under Management As of March 20, 2026, we managed clients’ accounts valued at approximately $129,534,296 on a discretionary basis. ITEM 5: FEES AND COMPENSATION Advisory Services Our fees are based on an annualized percentage of the market value of your portfolio’s assets under our management. Our standard fee schedule for investment management services is: Assets Under Management Under $1,000,000 1.25% $1,000,000-$3,000,000 1.00% Over $3,000,000 0.75% We bill our fees quarterly, in advance, as specified in our investment management agreement with you. We calculate our fee on the total market value of the securities, including bank deposits and cash balances, under our management, as of the last trading day of the preceding quarter, as re- ported by the account custodian. When our services are engaged any time other than the beginning of a calendar quarter, our fees will be prorated. The prorated fee amount will be based on initial deposit total market value as described above and time remaining in the quarter, as specified in investment management agreement with you. We generally do not prorate our fees with respect to additions to, or withdrawals from, your account during any quarter; however, fee adjustments may be made on a case- by-case basis when appropriate and in consultation with you. We appreciate advanced notice of anticipated additions or withdrawals so that we can better plan for the manage- ment of your account. Our investment management fees are negotiable and agreed upon at the time of our engagement. We may agree to a fixed management fee for certain accounts. If you, your family or related per- sons also have accounts under our management, those accounts may be aggregated for fee calcu- lation purposes. We may negotiate our fees taking into consideration such things as the size of your account, the number of managed portfolios, your relationship with other clients, the length of our relationship with you, the complexity of your personal circumstances, the composition of your portfolio, the complexity of investment strategies, the frequency of desired meetings or special reporting, and other factors that affect our cost of providing services for you. For these reasons, Burnham and Company LLC Page 2 ADV Part 2A – 6/10/26  our fees may vary among clients who may appear to be in similar circumstances. Other investment advisers may charge higher or lower fees for comparable services. Retirement Plan Consulting Our fees are based on an annualized percentage of the market value of the retirement plan’s assets as reported by the recordkeeper or custodian. Our standard fee schedule for retirement plan con- sulting is: Assets Under Management Under $1,000,000 0.80% $1,000,000-$3,000,000 0.60% Over $3,000,000 0.40 Generally, we bill our fees quarterly, in advance, as specified in our retirement plan consulting agreement with you. However, some recordkeeper may charge at a different interval. This will be disclosed in the retirement plan consulting agreement. We calculate our fee on the total market value of the securities, including bank deposits and cash balances, under our management, as of the last trading day of the preceding quarter, as reported by the account custodian or recordkeeper. When our services are engaged any time other than the beginning of a calendar quarter, our fees will be prorated. The prorated fee amount will be based on initial deposit’s total market value as described above and time remaining in the quarter, as specified in retirement plan consulting agree- ment with you. We generally do not prorate our fees with respect to additions to, or withdrawals from, your account during any quarter; however, fee adjustments may be made on a case-by-case basis when appropriate and in consultation with you. We appreciate advanced notice of anticipated additions or withdrawals so that we can better plan for the management of your account. Our retirement plan consulting fees are negotiable and agreed upon at the time of our engagement. We may negotiate our fees taking into consideration such things as the size of the plan, number of participants, the number of portfolios, ERISA based services, the length of our relationship with plan or the plan sponsor, the frequency of desired meetings or special reporting, and other factors that affect our cost of providing services for you. For these reasons, our fees may vary among plans that may appear to be in similar circumstances. Other investment advisers may charge higher or lower fees for comparable services. Direct Billing to Your Custodian or Recordkeeper Generally, clients authorize us under our investment management agreement, retirement plan con- sulting agreement, recordkeeper, and/or the custodian authorization form to directly deduct our fee from their account(s). If you provide us with such authorization, your fee payment will show on your custodian statement. You may terminate this fee deduction at any time by giving us written notice. For investment management clients, you can direct us to withdraw the fees for multiple accounts from a particular account. This can only be done with accounts titled the same. If you request an invoice, your payment is due by check within 10 days following receipt of our billing invoice. Burnham and Company LLC Page 3 ADV Part 2A – 6/10/26  Transaction Fees and Other Expenses Our investment management fees and retirement plan consulting fees do not include brokerage commissions, transaction fees, and other related costs and expenses incurred in connection with providing our services to you. Notably, most custodians have now adopted zero-cost trading for equities, which we intend to utilize. Some of our investment strategies include mutual funds, index funds, exchange-traded funds and/or other types of funds All fees paid to us for our services are separate and distinct from the fees and expenses charged by these funds to their shareholders. These fees and expenses are described in each fund’s prospectus and potentially include a man- agement fee, distribution fee (i.e., Rule 12b-1 fee), sales charge and other fund expenses. It is important for you to understand that if you are invested in funds that charge a management fee, shareholder service, or other fund expense, you are directly and indirectly paying two levels of advisory fees and expenses: one layer of fees and expenses at the fund level and one layer of advisory fees to us. Generally speaking, you could invest directly in many mutual funds without the benefit of our services and incurring our advisory fees. We can recommend mutual funds that would normally charge a front-end sales load; however, our clients will not be subject to front-end loads. Some mutual funds impose deferred sales charges for selling within a short time frame, sometimes up to a year; however, we do not recommend mutual funds as short-term investments, so deferred sales charges are unlikely to apply in most circumstances unless you choose to make a withdrawal and need to liquidate your shares in the fund. Termination We look forward to a long-term relationship with you. In the event that you or we ever desire to terminate our relationship, 10 days’ written notice is all that is required. You will automatically receive a prorated refund of fees paid for periods beyond the termination date. Termination of our agreement shall not affect liabilities or obligations incurred from transactions initiated under our agreement prior to the termination date, such as the purchase of investments by us for your account. You are responsible for any cost incurred in transferring assets from your account to a different account. After the termination date, we shall have no further duties or obligations to you under our agreement. Retirement Rollover Conflicts of Interest 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 of interest with your inter- ests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees. We do not charge fees based on a share of your ac- count’s capital gains or the capital appreciation of assets held in your account. Burnham and Company LLC Page 4 ADV Part 2A – 6/10/26  ITEM 7: TYPES OF CLIENTS We provide investment management services to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, and charitable organizations, and companies. We do not require a minimum account size to become a client. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis We mainly use a fundamental method to analyze the securities that we recommend as investments. Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the economic well-being of a company, as opposed to movements of its market price. In the course of our analysis, we will review a company’s financial statements and consider factors including, but not limited to, the company’s historical financial condition, prior operating results and trends, its projected revenue growth, its competitive advantages and disadvantages, the anticipated de- mand for its current and future products or services, the age and nature of its assets, and other factors affecting the company’s anticipated results from future operations. Past performance does not assure similar future performance. A company’s fundamental value can be adversely affected by many factors unrelated to its actual operating performance. As a result, we will also consult various industry and technical resources to formulate an appropriate price, time, and strategy to take a position in a new security or an appropriate exit strategy to sell a security in your portfolio. Unlike fundamental analysis, technical analysis does not analyze the company’s value, but instead analyzes the movement of stock prices in the market, both individually and within an industry or sector of the economy. Technical anal- ysis studies the supply and demand in the market in an attempt to determine historical and future trends. Notwithstanding favorable market price movements, a company’s financial condition and other unique factors can adversely affect its value. We obtain information from a number of sources both public and by purchase, including financial newspapers and magazines, our own inspection of corporate activities; research materials prepared by third-parties, corporate rating services, annual reports, prospectuses, filings with the SEC and company press releases. We consult these resources as we make our investment decisions. Investment Strategies Our investment strategies are designed with the needs and goals of the particular client. Thus, depending on the client’s circumstances, we may recommend long-term purchases (held at least a year), short-term purchases (held less than a year) and options. We may recommend implementing these strategies using stocks and other equity securities, bonds and other fixed income securities, government and municipal securities, option contracts, mutual funds, exchange traded funds, Burnham and Company LLC Page 5 ADV Part 2A – 6/10/26  private equity, private credit, real estate investment trusts, structured notes, and sometimes other types of investments. Investment Risks and Rewards Our investment strategies are oriented towards long-term growth. Generally, we invest in individ- ual companies that have a superior market history when compared to its peers, and historic ranges. The equities we consider for investment must have an above average earning potential. Where appropriate, we also look for companies with a global presence. We attempt to manage portfolio risk by emphasizing high standards of quality, appropriate diversification and limited volatility relative to the market. Investing in securities involves risks of loss that clients should be prepared to bear. The securities we recommend all bear different types and levels of risk. These risks will be discussed with you to determine the investment objectives that will guide our investment decision-making for your account. Upon request, we can discuss with you the types of investments and investment strategies that we believe may tend to reduce these risks in light of your personal circumstances and financial objectives. Obtaining higher rates of return on investments typically entails accepting higher levels of risk. Based upon discussions with you, we will attempt to identify the balance of risks and rewards that are appropriate and comfortable for you. It is still your responsibility to ask questions if you do not understand fully the risks associated with any investment or investment-strategy. We strive to render our best judgment on your behalf. Still, we cannot assure you that your in- vestments will be profitable or assure you that no losses will occur in your investment portfolio. Past performance is one relatively important consideration with respect to any investment or in- vestment advisor, but it is not a predictor of future performance. While we will continuously strive to provide outstanding long-term investment performance for you and our other clients, many eco- nomic and market variables beyond our control can affect the performance of your investments. There are many types of risks, which vary with the type of investment or strategy. We would be happy to discuss them with you. Generally, some of the more common investment-related risks that may affect your investment portfolio include:  Business risks are associated with a particular company or industry. For example, start-up companies carry greater business risks than established companies. Companies developing new technologies carry greater business risks than manufacturers of well-established or widely used products and services.  Cybersecurity risk is associated with services provided by advisors, custodians, and other industry service providers. We rely on a number of third-party service providers in the conduct of our business, including custodians, broker-dealers, administrators, technology vendors, portfolio management and reporting platforms, and providers of communications and data services. Cybersecurity incidents affecting any of these service providers may adversely affect us and our clients even if our own systems are not directly compromised. Burnham and Company LLC Page 6 ADV Part 2A – 6/10/26  We have limited ability to assess, monitor, or control the cybersecurity practices of our service providers, and clients may have limited or no recourse against such service provid- ers in the event of a cybersecurity incident.  Financial risks are often associated with the ability of a company to raise capital or finance its operations, as well as its ability to repay indebtedness. Highly leveraged companies face greater financial risks than well-capitalized companies.  Market risks are related to the effects of economic, political, natural disasters, or other events on the price of a publicly-traded stock, bond, exchange-traded fund, or other secu- rities. This type of risk is typically affected by extrinsic factors that often are not related to a particular company’s financial condition, performance, or circumstances. For exam- ple, investment speculation can materially affect market prices.  Liquidity risks are associated with an investor’s ability to readily convert a security or other asset into cash. Generally, there is greater liquidity for securities that are publicly traded on stock exchanges or trading facilities that match buy and sell orders. Privately offered securities may be highly illiquid because there is little or no trading or market activity.  Concentration risks result from a lack of investment diversification, which may be ex- pressed in terms of geography, industry, or economic sector. For example, investing a high percentage of a portfolio in companies serving one sector of our economy increases its concentration risk. Advancements in technology, new product development, government tax and fiscal policy, or changes in consumer buying habits and preferences could signifi- cantly affect all of the companies operating in a particular economic sector more than oth- ers.  Options are complex, derivative securities that involve special risks. Option contracts ex- pire at a stated maturity date and have no further value. Unlike traditional securities, the value of an option and the return from holding an option varies with the value of the un- derlying security from which it derives and other factors.  Interest-rate risks are associated with changes to investment prices due to increasing or decreasing interest rates. For example, when interest rates rise, yields on newly issued bonds become higher, making them more attractive than yields on already outstanding bonds, which may cause the market values of outstanding bonds to decline.  Inflationary and deflationary risks are associated with the purchasing power of the dollar, which is affected by broad economic, monetary, governmental policies, and the balance of supply and demand for products and services.  Reinvestment risks are typically related to fluctuations in the potential interest rate at which future investment proceeds may have to be invested. For example, reinvestment risks may increase during periods of falling interest rates. This risk primarily relates to bonds and other fixed income securities. Burnham and Company LLC Page 7 ADV Part 2A – 6/10/26   Currency risks are primarily associated with foreign investments. For example, a com- pany’s earnings in a foreign country may be affected by fluctuations in the value of the dollar against that foreign currency. Similarly, the investment return of a foreign security may be affected by changes in currency exchange rates. Risks Associated with Certain Securities  Private Equity and Private Credit - Illiquidity and Long-Term Commitment. Interests in private equity or private credit funds are highly illiquid. With non-traded private equity and credit, investors can be required to commit capital for the life of the fund, which is typically ten to twelve years or longer, and may be subject to extensions at the discretion of the general partner. There is no public market for this type of private equity or private credit interests, and transfers are generally prohibited or significantly restricted by the gov- erning documents of the fund. Clients should not invest in private equity unless they can afford to have their capital tied up for an extended period and have no foreseeable need to access the invested funds. For exchange-traded private equity and private credit funds li- quidity if often available only once a year with a limited amount of shares available to redeem. Clients should know that they may not be able to readily redeem their investment even though it is traded on an exchange.  Private Equity and Private Credit Risk of Loss. Private equity and private credit invest- ments are speculative and involve a substantial risk of loss, including the loss of the entire amount invested. Portfolio companies are often highly leveraged, may operate in volatile industries, and may fail to achieve projected performance or fail entirely. Returns are also subject to valuation uncertainty, as portfolio investments are not traded on public markets and are valued by the general partner using subjective methodologies that may not reflect the price ultimately realized upon disposition.  Fund Leverage Risk: Certain funds recommended by us may use leverage. This means the fund uses derivatives to increase the Fund's combined long and short exposure, which creates leverage. Leverage can magnify the Fund's potential for gain or loss and, therefore, amplify the effects of market volatility on the Fund's share price.  Structured Note - Issuer Credit Risk. Structured notes are unsecured debt obligations of the issuing financial institution, and all payments of interest, contingent coupons, and prin- cipal — including any principal protection feature — are subject to the credit risk of the issuer. Structured notes are not deposits and are not insured by the Federal Deposit Insur- ance Corporation or any other governmental agency. If the issuer becomes insolvent or otherwise fails to perform its obligations, investors may lose some or all of their investment regardless of the performance of the underlying reference asset, and regardless of any stated principal protection, buffer, or guarantee feature of the note. Investors should eval- uate the creditworthiness of the issuer independently of the structure of the note itself.  Structured Note - Risk of Loss Tied to Reference Asset Performance. The return on a structured note, and in many cases the return of principal at maturity, is linked to the per- formance of one or more underlying reference assets, such as equity indices, individual Burnham and Company LLC Page 8 ADV Part 2A – 6/10/26  stocks, commodities, currencies, interest rates, or baskets of such assets. Depending on the structure of the note, adverse movements in the reference asset may result in reduced or no coupon payments, the loss of some or all of the principal invested, the early call of the note at a time disadvantageous to the investor, or the physical delivery of a depreciated under- lying asset in lieu of cash. Features such as buffers, barriers, and contingent principal pro- tection apply only within defined parameters and may provide no protection if the reference asset breaches a specified threshold. The payoff structure of a structured note is generally asymmetric, meaning that the investor's upside is typically capped or otherwise limited while the downside exposure may be substantial or unlimited within the terms of the note.  Structured Note - liquidity and valuation. There is typically no active secondary market for structured notes. Dealer bids when available are often well below the issuer's estimated value, and the initial estimated value of the note on the pricing date is generally lower than the issue price due to embedded fees, hedging costs, and dealer compensation. ITEM 9: DISCIPLINARY INFORMATION We have no legal or disciplinary events to disclose. As a registered investment adviser, we are required to disclose to you all material facts regarding any legal or disciplinary events that would be material to your evaluation of our firm or the integrity of our management. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Neither our Firm nor our representatives are engaged in any other business that is material to our investment advisory business. We have no affiliations with other service providers such as broker- dealers, other investment advisers, banks, or custodians. We do not recommend or select invest- ment advisers for our clients ITEM 11: CODE OF ETHICS, PARTICIPATION, OR INTEREST IN CLIENT TRANS- ACTIONS AND PERSONAL TRADING We have adopted a Code of Ethics describing the standards of business conduct we expect our firm and our representatives to follow. It imposes certain reporting requirements for our represent- atives. Our Code of Ethics helps us to assure that our firm and our representatives will act in your best interests. Our Code of Ethics is designed to: (1) protect our clients by deterring misconduct; (2) educate our employees regarding the firm’s expectations and the laws governing their conduct; (3) remind our representatives that they are in a position of trust and must act with honesty, integrity and profes- sionalism at all times; (4) protect our firm’s reputation; (5) guard against violations of the securities laws and rules; (6) establish procedures for representatives to follow to assure compliance with our firm’s ethical principles. Burnham and Company LLC Page 9 ADV Part 2A – 6/10/26  Our representatives must comply with all applicable securities laws and rules. Our representatives may not, in the connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by a client: (1) defraud the client in any manner; (2) mislead the client, including by making a statement that operates as a fraud or deceit upon such client; (3) engage in any act, practice, or course of conduct which operates as a fraud or deceit upon such client; (4)engage in any manipulative practice with respect to such client; (5) engage in any manipulative practice with respect to securities, including price manipulation. You may request a copy of our Code of Ethics by contacting our firm at the address or telephone number given on the cover page. Putting Clients First Our Code of Ethics includes a Personal Securities Trading Policy. Among other things, that policy requires our representatives to abide by policies and procedures for personal securities trading. Generally, we do allow our representatives to trade for their own personal and immediate family (i.e., spouse and minor children), in a security actively purchased or sold on behalf of our clients, but we have safeguards that are intended to put clients’ interests first. We require that all client orders be placed and filled before any comparable orders are placed for personal accounts in the same publicly-traded security. For example, this means that clients’ buy orders are placed and filled before personal buy orders; similarly, clients’ sell orders are placed and filled before personal sell orders. Under some circumstances, we may further require that personal trades be placed a minimum period of time after clients’ trades. We prohibit any and all trading on inside infor- mation. We also monitor personal trading activity for conduct that is inconsistent with our clients’ interests. Our clients and our representatives generally trade in widely-held, publicly-traded securities. The volume of our clients’ and personal trading is typically a very small percentage of a security’s daily trading volume, which mitigates the risk that any client account might be disadvantaged, or a personal account inappropriately advantaged by our trading activities. ITEM 12: BROKERAGE PRACTICES You may grant us discretion to select the brokerage firms to use in buying and selling securities for their portfolios. We will use our best efforts to negotiate brokerage commissions, concessions, and charges on behalf of your account. We seek to obtain the best execution for your account by which your total cost or proceeds will be more favorable under the circumstances, which may include other factors beyond price and cost. You are also free to select one or more custodians/brokerage service to hold your investments. When your custodian is a broker-dealer, we typically ask for your direction to use that brokerage firm to execute all trades for the account because of the efficiencies and convenience of doing so and additional custodial charges that may be incurred if a different custodian is used. Therefore, your selection of custodians may materially affect our ability to obtain the lowest price or cost in any particular transaction. Most of our clients choose to direct us to use a specific broker-dealer Burnham and Company LLC Page 10 ADV Part 2A – 6/10/26  and custodian. We periodically check with various brokerage firms about their commissions, con- cessions, and charges. We use many different brokerage firms for various clients’ accounts. We have many clients who choose to use Charles Schwab & Co., Inc. and Fidelity Brokerage Services LLC, as brokerage firms. Fidelity Brokerage Services LLC and Charles Schwab & Co, Inc. provide us with “institutional platform services.” These services primarily include, among others, brokerage, custody, and other account-related services. The institutional platform services assist us in managing and adminis- tering your account. The platform includes software and other technology that (i) provides access to client account data (such as trade confirmations and account statements); (ii) facilitates trade execution for multiple clients accounts at the same time; (iii) provides research, pricing, and other market data; (iv) facilitates payment of fees from clients’ accounts; and (v) assists us with some back-office functions, recordkeeping and client account reporting. They also offer other services intended to help us manage and further develop our professional practice. Those services include, for example, performance reporting, financial planning, contact management systems, third-party research, compliance and other publications, access to educa- tional conferences, roundtables, and webinars, practice management resources, access to consult- ants, and other third-party service providers who offer a wide array of business-related services and technology with whom we may contract directly. These services are offered to all qualifying investment advisers whose clients have Fidelity and Schwab accounts. We are not affiliated with Fidelity or Schwab. Fidelity and Schwab generally do not charge our clients separately for custody services but, in- stead, they are compensated through the brokerage commissions and other transaction-related or asset-based fees for your securities trades that are executed through them or that settle into your accounts. For example, compensation may include brokerage commissions, sales charges, and other payments described in each mutual fund’s prospectus. Investment Research and “Soft Dollars” “Soft dollars” are defined as a form of payment investment firms can use to pay for goods and services such as news subscriptions or research. When an investment firm gives its business to a particular brokerage firm, the brokerage firm in return can agree to use some of its revenue to pay for these types of services. We do not receive any soft dollars from a qualified custodian. Brokerage For Client Referrals We do not receive client referrals or any other incentive from any broker-dealer or custodian. Directed Brokerage You are welcome to select your preferred brokerage firm and/or custodian for your account. You may elect to direct us to use a specific brokerage firm because, for example, you have a pre-existing relationship with the broker. All directed brokerage requests and changes must be provided to us in writing. From time to time, we may ask you to confirm your continuing direction to use a Burnham and Company LLC Page 11 ADV Part 2A – 6/10/26  brokerage firm to handle all of your orders. We are not affiliated with any brokerage firm and so we do not earn any additional compensation on brokerage transactions. Many clients select a brokerage firm because it also provides custodial services, either directly or through a clearing brokerage firm. Often, a brokerage firm does not impose additional charges for related custody services. Most brokerage firms do not separately charge for their custodial services if you use their brokerage services. However, when the brokerage services of a different firm are used for a particular transaction, most custodial brokerage firms charge an additional fee because they must handle the custodial aspects of the transaction and related recordkeeping but do not receive compensation from the transaction itself. Therefore, most clients direct us to use the same brokerage firm to both hold custody of their investments and to place most or all trade orders for their accounts. While directed brokerage can reduce or avoid additional custodial fees for your account, there are some disadvantages to directed brokerage arrangements such as:  Using a brokerage firm to act as custodian may limit or eliminate our ability to obtain best price and execution for the account in some transactions involving exchange-traded secu- rities.  We negotiate commissions with each brokerage firm and, in many instances, obtain better than those firms’ standard rates for comparable transactions. However, if we cannot choose a different brokerage firm to handle specific transactions, then in some transactions you may pay substantially higher brokerage fees, charges and/or dealer mark-ups or mark- downs than could be obtained if we could have placed the trade with a different brokerage firm.  When we cannot go directly to a market maker to buy or sell a particular security on a principal basis, you may not get the best execution price in the transaction or may pay additional transaction-related fees for a transaction handled on their behalf on an agency basis. This is because your brokerage firm may fill the orders by going to a market-making contra broker, who may mark-up the securities it sells (or mark-down the securities it buys), imposing transaction costs that are in addition to the commissions you pay to the brokerage firm that serves as your custodian.  When trades in exchange-listed securities are effected on an agency basis in an off-ex- change over-the-counter market, you may incur transaction costs in addition to any com- missions charged by your custodial brokerage firm. Trade Aggregation We can aggregate transactions in equity and fixed income securities for a client with other clients to improve the quality of execution. When transactions are aggregated, the actual prices applicable to the aggregated transactions will be averaged, and each client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. We can determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, the liquidity of the securities or the Burnham and Company LLC Page 12 ADV Part 2A – 6/10/26  discretionary or non-discretionary nature of the trades. If we do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that the practice of not aggregating may cost clients more money. ITEM 13: REVIEW OF ACCOUNTS Reviews and Reviewers Generally, we review all our accounts every 15 to 30 days. We believe this frequency of review is vital. We may review accounts more frequently if circumstances warrant, such as significant eco- nomic or political events or developments. Accounts are reviewed by Adam R. Trask and Bob Tsironis. Reviews are important to better assure that your investments are and remain in sync with your investment objectives. Reviews are con- ducted for individuals, high net worth individuals, institutions and qualified retirement plans. Reports and Account Statements We will provide you with portfolio appraisal reports at our review meetings. These reports show all the securities you then hold, the number of shares, your cost basis, and their current value. Upon request, we also provide reports showing all transactions in your account for the quarter. Addi- tional reports are available at your request. Our periodic reports are in addition to your custodian’s periodic account statements. Your custo- dians will also provide account statements at least quarterly showing the current positions in your account and all account activity during the reporting period, including management fees paid from your account to us. As described in more detail in Item 15: Custody below, we urge you to review your statements. We rely upon, and are not responsible for, the accuracy of the custodian’s account statements. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION We do not have any promoter agreements. We do not compensate directly or indirectly any persons for client referrals. We strive to adhere to the highest ethical standards in performing our invest- ment advisory services. We do not employ or pay third-party solicitors to refer new investment advisory business to us. We have no conflicts of interest to disclose. We do not receive any other compensation from any third parties for services provided to our clients. ITEM 15: CUSTODY While we do not have physical custody of the assets held in your account, as described under the heading above, “Fees and Compensation,” we are deemed to have custody when you authorize us to deduct our management fees from your account. We have no other authority to withdraw or transfer assets from your account. Burnham & Company LLC also is deemed to have legal custody Burnham and Company LLC Page 13 ADV Part 2A – 6/10/26  over the assets of Burnham & Company clients who authorize us to direct their client custodian(s) to direct transfers to third parties pursuant to standing instructions. Your account assets must be maintained by an independent qualified custodian. You should re- ceive at least quarterly, account statements from the broker dealer, bank or other qualified custo- dian that holds and maintains your investment assets. Your custodian’s statements are in addition to our reports. We urge you to carefully review and compare our reports with your custodian’s account statements for consistency and accuracy. Do note that our reports and the custodian’s account statements may be as of different dates and there could be minor differences between the values contained the respective reports. Promptly contact us or your custodian if you find mate- rial differences between our reports and the custodian’s account statements or if you have any questions. ITEM 16: INVESTMENT DISCRETION As explained under the heading above, “Advisory Business,” in our investment management agree- ment you grant us discretionary authority over your account, including authority to select the iden- tity and amount of securities to be bought or sold for your benefit and risk. Our discretion will be exercised in accordance with your stated investment objectives. You may provide us with written investment guidelines or restrictions to limit our discretionary authority. ITEM 17: VOTING CLIENT SECURITIES We do not vote proxy votes for any client. All proxy materials are mailed or emailed directly to the client from the custodian. Any proxy materials received by us will be forwarded to clients for response and voting. In the event the client has a question about a proxy solicitation, the client should feel free to contact us. ITEM 18: FINANCIAL INFORMATION We are required to provide you with certain financial information or disclosures about our financial condition if we have financial commitments that impair our ability to meet contractual and fiduci- ary commitments to you or if we were to require prepayment of our advisory or financial planning and consulting fees in excess of $1,200 per client, six months or more in advance. We have no financial liabilities, obligations, or commitments that impair our ability to meet our contractual and fiduciary commitments to you. We have not been the subject of a bankruptcy proceeding. Fees for advisory services are collected quarterly in advance only. Burnham and Company LLC Page 14 ADV Part 2A – 6/10/26