CAPE ANN CAPITAL, INC.

December 31, 2025 FIRM BROCHURE (PART 2A OF FORM ADV) Cape Ann Capital, Inc. 22 Grove Street Concord, MA 01742 (978) 254-5841 (O) (978) 816-9531(C) (978) 254-5461 (F) www.capeanncapital.com jimj@capeanncapital.com This brochure provides information about the qualifications and business practices of Cape Ann Capital, Inc. If you have any questions about the contents of this brochure, please contact Jeremy DiStefano at (617) 548-1755 or at jeremyd@capeanncapital.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Registration with the SEC or a state securities authority does not imply a certain level of skill or training. Additional information about Cape Ann Capital, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. Firm Brochure–Part 2A of Form ADV 1 December 31, 2025  ITEM 2: MATERIAL CHANGES Material Changes since the Last Annual Update This summary includes material changes since we last updated our brochure on December 31, 2025. • Firm ownership change: James Jasinski will own 50% and Jeremy DiStefano will own 50% as of 3/31/2026. • The ownership prior to 3/31/2026: David Umstead 33.3%, James Jasinksi 33.3% and Jeremy DiStefano 33.3%. • Assets under management went from $199 million to $193 million as of 12/31/2025. • The number of client portfolios went from 256 to 234 as of 12/31/2025. • Our 234 portfolios comprise 549 accounts as of 12/31/2025. • We have full discretion for 543 client portfolios as of 12/31/2025. • We manage numerous portfolios that span multiple custodians. We are currently working with eleven custodians. About 90% of our assets under management are custodied at Fidelity as of 12/31/2025. • Our annual scan of all mutual funds and ETFs available to US investors resulted in several changes to our buy list for 2026. We added four new funds. Our buy list comprises 11 mutual funds and ETF’s. • Each of our fourteen models are blends of two or three sub-models. We have sub- models for: US cash, US bonds and Global Stocks. Firm Brochure–Part 2A of Form ADV 2 December 31, 2025  ITEM 3: TABLE OF CONTENTS ITEM 2: MATERIAL CHANGES ...................................................................... 2 Material Changes since the Last Annual Update ................................. 2 ITEM 3: TABLE OF CONTENTS ..................................................................... 3 ITEM 4: ADVISORY BUSINESS .................................................................... 5 Firm Description ................................................................................ 5 Principal Owners ............................................................................... 5 Types of Advisory Services ................................................................ 5 Wrap Fee Programs ........................................................................... 5 Assets Under Discretionary Management ........................................... 6 ITEM 5: FEES AND COMPENSATION ............................................................ 6 Description ........................................................................................ 6 Fee Billing .......................................................................................... 6 Other Expenses ................................................................................. 6 Participation or Interest in Client Transaction ................................... 7 ITEM 6: PERFORMANCE-BASED FEES ......................................................... 7 ITEM 7: TYPES OF CLIENTS ......................................................................... 7 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................................................................. 8 Methods of Analysis and Investment Strategies ................................ 8 Risk of Loss ....................................................................................... 9 ITEM 9: DISCIPLINARY INFORMATION ..................................................... 10 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................................................... 10 Broker-Dealer Registration .............................................................. 10 Futures, Commodity Pool Operator, Commodity Trading Adviser ..... 10 Related Person Arrangements ......................................................... 10 Arrangements With Other Investment Advisers .............................. 11 ITEM 11: CODE OF ETHICS ........................................................................ 11 Code of Ethics .................................................................................. 11 ITEM 12: BROKERAGE PRACTICES ............................................................ 12 Selecting Brokerage Firms ............................................................... 12 Research and Other Soft Dollar Benefits .......................................... 12 Brokerage for Client Referrals ......................................................... 12 Directed Brokerage .......................................................................... 12 Aggregation of Client Accounts ........................................................ 12 ITEM 13: REVIEW OF ACCOUNTS .............................................................. 13 Periodic Reviews ............................................................................. 13 Review Triggers ............................................................................... 13 Firm Brochure–Part 2A of Form ADV 3 December 31, 2025  Regular Reports ............................................................................... 13 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ...................... 13 Incoming Referrals .......................................................................... 13 Referrals Out ................................................................................... 13 Other Compensation ........................................................................ 13 ITEM 15: CUSTODY ................................................................................... 14 ITEM 16: INVESTMENT DISCRETION ......................................................... 14 ITEM 17: VOTING CLIENT SECURITIES ..................................................... 14 Proxy Votes ..................................................................................... 14 ITEM 18: FINANCIAL INFORMATION ........................................................ 14 ITEM 19: REQUIREMENTS FOR STATE-REGISTERED ADVISERS ................. 14 Firm Brochure–Part 2A of Form ADV 4 December 31, 2025  ITEM 4: ADVISORY BUSINESS Firm Description Cape Ann Capital was founded in April of 1999 to provide investment advisory services to individuals and institutions. The firm manages 234 portfolios with a consolidated market value of $193 million. Principal Owners James Jasinski and Jeremy DiStefano each own one-half of the firm as of 3/31/2026. Prior to that the split was David Umstead 33.3%, James Jasinski 33.3%, Jeremy DiStefano 33.3%. Types of Advisory Services Cape Ann Capital manages portfolios of actively managed mutual funds for individuals, trusts, corporations and charities. Each client portfolio is tailored to a long-term asset allocation target determined by the client. Cape Ann Capital assists in finding an asset allocation target that will meet each client’s long-term return objectives without exceeding his or her tolerance for risk. Our risk targets are a blend of US Cash, U.S. bonds and global equities. Allocations across these three categories vary considerably from client to client. Cape Ann Capital partners with independent service providers to manage and administer open architecture qualified retirement plans to employers. These plans typically replace a captive plan, for which all services were provided by a single mutual fund company. An open architecture plan removes conflicts of interest in the selection of investments offered to participants and makes costs much more transparent. Cape Ann Capital is the independent advisor. An independent trustee provides brokerage and custody. An independent third-party administrator (TPA) provides structure to plan through compliance testing, census work and filing documents with the IRS. An independent recordkeeper processes and reconciles account activity and provides participants with account valuations. Cape Ann Capital manages participant portfolios using the same investment process as for all other clients. Cape Ann Capital is committed to open architecture retirement plan solutions and is willing to work with a wide variety of independent partners. Cape Ann Capital provides portfolio management services for three multi-participant, employer-sponsored qualified retirement plans. Cape Ann Capital offers financial planning services for an additional fee. We help clients construct household balance sheets and income and expense projections towards various financial goals. The projections incorporate estimates of social security income, Federal and state income taxes, required minimum distributions from retirement accounts as well as current assets and the expected returns and risks of these assets. Wrap Fee Programs Cape Ann Capital does not participate in any wrap fee programs. Firm Brochure–Part 2A of Form ADV 5 December 31, 2025  Assets Under Discretionary Management Discretionary assets under management total $181 million. ITEM 5: FEES AND COMPENSATION Description Our asset management fees are based on the market value of the assets being managed and are calculated according to the following fee schedule. Fee Schedule Assets Annual Fee Rate First $1 million Over $1 million 0.80% of assets 0.20% of assets Cape Ann Capital’s minimum fee is $300 per month. Accounts below $450,000 in assets pay a higher annual fee rate than the 0.80% shown above. Clients using custodians that do not link electronically to Orion (our portfolio reporting software) will be charged 0.90% of assets on the first $1 million. Cape Ann Capital charges a $500 set up fee in cases where our initial setup work is more than ten hours of labor. Cape Ann Capital’s annual financial planning fees are $3,000. Fees are negotiable. Fee Billing In most cases, Cape Ann Capital invoices fees monthly (at one-twelfth the annual rate), in arrears based on month-end valuations. Fees for the first month are pro-rated from the first day assets arrive at Fidelity. Cape Ann Capital submits fee invoices to Fidelity. Fidelity debits our monthly fee directly from client accounts. The fee billing arrangements in the open architecture qualified plans vary from plan to plan. In some cases, the record keeper calculates and collects our fee. In other cases, the plan sponsor pays us directly. Other Expenses Cape Ann Capital uses Fidelity for most custody and discount brokerage. Clients may incur brokerage and other transaction costs. Further information on brokerage fees is provided at Item 12 in this brochure. Firm Brochure–Part 2A of Form ADV 6 December 31, 2025  All mutual funds have internal operating expenses, which are debited from the fund and therefore paid by the client. These fees are in addition to the fees charged by Cape Ann Capital. Most mutual funds offer transaction fee (TF) shares and no-transaction-fee (NTF) shares. As a fiduciary it is our responsibility to buy the share class which is in the best interest of each client. For every purchase we must decide if it is worth paying a one-time commission to obtain a higher rate of return. The math dramatically favors NTF shares for investors with funding programs that make numerous small purchases. It makes no sense to pay $20 every month to invest $100. On the other hand, investors making large purchases are much better off paying $20 to get a higher rate of return for as long as they hold the fund. The increased return, from avoiding the 12b-1 distribution fee included in NTF shares, is typically 0.25% per year. For a million-dollar investment this amounts to a $2,500/year value which compounds over time. Since this higher return is simply an expense reduction it comes without risk. Cape Ann Capital configures its systems to buy the share class that will likely lead to the highest wealth accumulation for the client. But this is a complicated and imprecise calculation which for most of our buy decisions is no longer necessary because of a game-changing innovation by Fidelity. At Fidelity we can buy the higher return share class without a commission. Fidelity has used its clout in the marketplace to get many mutual fund companies to absorb this cost. Participation or Interest in Client Transaction Cape Ann Capital receives no compensation for the sale of securities or other investment products and therefore has no incentive to select one investment over another. ITEM 6: PERFORMANCE-BASED FEES Cape Ann Capital does not accept performance-based fees, flat fees or hourly fees. ITEM 7: TYPES OF CLIENTS Cape Ann Capital provides investment advisory services to: • high net worth individuals, • individuals, • qualified plans, • • • trusts, corporations, and charities. Generally, Cape Ann Capital does not require a minimum account size (though it does enforce a minimum monthly fee of $300, as mentioned in Item 5) Firm Brochure–Part 2A of Form ADV 7 December 31, 2025  ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis and Investment Strategies In most cases, Cape Ann Capital invests exclusively in mutual funds and ETFs Cape Ann Capital regularly evaluates every mutual fund and ETF in the country to identify those that have outperformed their benchmarks over the long term with a consistency that is very unlikely to have been achieved by chance. Cape Ann Capital employs various research tools to conduct ongoing analyses of these funds. Cape Ann Capital typically draws on its proprietary research to select a diversified mixture of actively managed mutual funds and ETFs that will deliver the long-term exposure desired by the client. Cape Ann Capital uses a multi-factor risk model to measure the effective asset allocation history of each mutual fund and to calculate a unique reference benchmark that is appropriate for each manager. This allows measuring a value manager against a value index, a bond manager against a bond index, a small cap manager against a small cap index, etc. Cape Ann Capital then calculates each manager's average excess return, the consistency of the excess return and a t-statistic that reflects the probability the result could have occurred by chance. Cape Ann Capital looks at additional factors such as investment process, corporate culture, management tenure, expense ratios, portfolio turnover and performance within Morningstar category to arrive at a final proprietary Buy List. Cape Ann Capital reviews its Buy List periodically to ensure that it always reflects the most skillful managers available. Constructing Portfolios: Every Cape Ann Capital client commits to a long-term asset allocation target and an upper limit on allowable tracking error relative to target. Cape Ann Capital uses an optimizer, a multi-factor risk model and proprietary excess return estimates for every fund on its buy list to identify an optimal model portfolio for each client. Optimal is defined as the portfolio with the highest expected return within the risk limit imposed by the tracking error constraint. The analysis takes account of the risk of each fund and the correlations among the funds. Cape Ann Capital sets lower and upper bounds on the size of each holding. Why Mutual Funds and ETFs There are many investment vehicles available to investors. Cape Ann Capital prefers mutual funds and ETFs for the following reasons: Firm Brochure–Part 2A of Form ADV 8 December 31, 2025  Transparency: Mutual funds and ETFs provide an investment vehicle with a publicly available track record. This allows us to evaluate all mutual fund and EFT managers on a consistent basis. It is very difficult to compare hedge funds or separately managed accounts because performance is often not readily available and is not provided by an independent third party. Professional Management: If a skillful mutual fund management team can achieve a higher return, net-of-expenses than the return of the asset classes in which they invest, this benefit accrues to the shareholders of the fund. Investors do not have to pay more for the services of a skilled manager vs. an unskilled manager. Investors would certainly be willing to pay a premium for skilled management, but because mutual funds exchange shares at net asset value the services of a skilled manager cost no more than the services of an unskilled manager. Cape Ann Capital seeks to identify mutual fund managers with more than enough skill to overcome the expenses of their fund and the expenses of Cape Ann Capital. Diversification: A single share of a mutual fund or ETF provides an investment in many individual securities. Lower Trading Commissions: Because mutual funds trade in large volume, they can negotiate much lower commissions when buying and selling securities. Liquidity: Mutual fund shares are redeemable daily. ETF shares trade tick by tick during the day. Load vs. No Load: Mutual funds come in two types; load funds and no-load funds. A load is a commission that goes to the salesperson who markets the fund. Cape Ann Capital's fund selection is driven by our fiduciary responsibility as a registered investment adviser. In that regard, we never buy load funds. Since no-load mutual funds do not have a sales force marketing their shares, they must rely primarily on performance to compete. Since expenses detract from performance, no-load funds tend to have lower expense ratios than load funds. Risk of Loss An investment in a mutual fund or an exchange traded fund involves a risk of loss. Client portfolios are generally invested in ten to fifteen mutual funds and/or ETFs. The mutual funds and ETFs on our Buy List invest in stocks and bonds as well as various derivative contracts such as foreign currency contracts, futures contracts, options contracts, and swap agreements. Investing in mutual funds and ETFs is risky because the underlying securities and derivative contracts fluctuate in value. These fluctuations may be due to political, economic, or general market circumstances. Some of these factors may Firm Brochure–Part 2A of Form ADV 9 December 31, 2025  affect a single company or industry and others may impact the broader market. Because the values of mutual funds and ETFs fluctuate, portfolios managed by Cape Ann Capital may decline in value. Investments in derivative instruments carry exposure to various risks such as, but not limited to, interest rates and foreign currency risk. Interest rate risk is the risk that a fixed income security will decline in value because of rises in interest rates. Foreign currency risk is the risk that a foreign currency or a security that is denominated in a foreign currency will decline in value. Derivative contracts also carry counter party risk, i.e. the risk that the entity on the other side of the contract will default. All these risks are mitigated by the fact that Cape Ann Capital portfolios typically hold numerous funds, and each fund holds hundreds or even thousands of securities. Through all this diversification Cape Ann Capital believes it can eliminate most of the idiosyncratic risk in client portfolios. Systematic risk can be controlled, but not eliminated. Each client commits to a long-term asset allocation target and the systematic risks associated with that target. One of the largest risks borne by Cape Ann Capital clients is the risk that they will capitulate on an aggressive asset allocation after suffering an extended period of market value declines and thereby convert an unrealized loss to a realized loss. ITEM 9: DISCIPLINARY INFORMATION Cape Ann Capital has never been involved in any kind of disciplinary proceedings in any court or with the SEC or with any other federal, state or foreign regulatory authority. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Broker-Dealer Registration We do not have a registration or an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Futures, Commodity Pool Operator, Commodity Trading Adviser We do not have a registration or an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. Related Person Arrangements Neither we nor any of our management persons have any relationship or arrangement that is material to our advisory business or to our clients that we have not otherwise disclosed. Firm Brochure–Part 2A of Form ADV 10 December 31, 2025  Arrangements with Other Investment Advisers We do not recommend or select other investment advisers for our clients nor do we have other business relationships with those advisers that create a material conflict of interest. ITEM 11: CODE OF ETHICS Code of Ethics Cape Ann Capital has a Code of Ethics that provides a standard of conduct for all employees. The Code requires that all employees conduct themselves in accordance with high ethical standards premised on the concepts of integrity, honesty, and trust. Every employee is held to a strict fiduciary standard. Every employee must always act in the best interest of the client and treat all clients fairly. A copy of the Code is available upon request. The following is a summary of certain provisions of the Code of Ethics: Confidential Information: As an investment adviser, we have a fiduciary duty to our clients not to divulge or misuse information obtained in connection with our services as an adviser. Therefore, all information, whether of a personal or business nature, that an employee obtains about a client's affairs during employment with us should be treated as confidential and used only to provide services to the benefit of the client. Such information may sometimes include information about non-clients, and that information should likewise be held in confidence. Even the fact that Cape Ann Capital advises a client should ordinarily be treated as confidential. Cape Ann Capital’s Code of Ethics sets forth steps that employees should take to help preserve confidential information. Material Inside Information: The Code of Ethics advises employees that purchasing or selling securities based on material nonpublic information for their own or a client’s account or “tipping” is a crime. Fiduciary Duty and Conflicts of Interest: Cape Ann Capital and its employees have a fiduciary duty to always act for the benefit of clients and to act on the clients’ behalf before acting to benefit themselves or the firm. The way any employee discharges his or her fiduciary duty and addresses a conflict of interest depends on the circumstances. Unfair Treatment of Certain Clients vis-à-vis Others: The Code prohibits employees from favoring one client over another. Personal Trading Policy: Cape Ann Capital’s Code is unusual in that it requires all employees to have all their personal investments managed by the company. Employees are not allowed to own or otherwise have a beneficial interest in any securities held in an account not managed by the company. Employees are not allowed any personal trading and their portfolios receive no preferential treatment over client portfolios. Firm Brochure–Part 2A of Form ADV 11 December 31, 2025  Each new employee must submit an initial holdings report disclosing to the Cape Ann Capital Chief Compliance Officer the identities, amounts, and locations of all securities owned in all accounts in which he or she has a "beneficial ownership interest." The management of these securities must be immediately turned over to Cape Ann Capital. The employee portfolio will be managed via the same process used for all client portfolios. The employee portfolio will be subject to all the reviews and reporting listed under Item 13. Employee portfolios look just like client portfolios. Each employee signs a management agreement and selects a risk level target. We run our optimizer to select the portfolio from our Buy List that comes closest to the employee’s long-run risk level target. ITEM 12: BROKERAGE PRACTICES Selecting Brokerage Firms Cape Ann Capital recommends Fidelity for all client brokerage transactions. No other broker offers a platform with thousands of mutual funds that can be bought and sold without commissions and without 12b-1 distribution fees. For more information on the unique benefits Fidelity offers refer to Other Expenses in ITEM 5. Research and Other Soft Dollar Benefits Cape Ann Capital accepts no research or soft dollar benefits from any broker. Brokerage for Client Referrals We do not consider whether we receive client referrals from a broker in selecting or recommending brokers. Directed Brokerage We routinely recommend Fidelity for custody and brokerage because they offer most of the mutual funds we need for our models at the lowest cost. In addition, we believe Fidelity’s reporting and cyber protection services are second to none. Aggregation of Client Accounts Mutual funds exchange shares at the market close. All clients buying or selling that day receive the same price. Accordingly, we do not aggregate trades as we do not have to be concerned with one client getting a better price than another. We use block trading when we trade ETFs. This ensures that all clients trading in a particular ETF on a particular day, get the same price. Firm Brochure–Part 2A of Form ADV 12 December 31, 2025  ITEM 13: REVIEW OF ACCOUNTS Periodic Reviews Cape Ann Capital reviews each client portfolio at least monthly. If the asset allocation of the portfolio is off target, we take steps to correct it. If any individual mutual fund is off target, we take steps to correct that as well. Cape Ann Capital periodically reviews all mutual funds and ETFs available to US investors. If we identify a fund or ETF that has demonstrated a higher skill level than a fund or ETF on the Buy List and the fund passes our due diligence check list, we make the substitution on our Buy List and adjust client portfolios accordingly. Review Triggers Cape Ann Capital monitors every mutual fund on the Buy List daily. If a fund displays a pattern of out-of-the-ordinary underperformance, we drop it from the Buy List and from client portfolios. Regular Reports Cape Ann Capital provides a Review for every client portfolio every month. The Review provides month-end market value, YTD profit, YTD Fees and net-of-fees performance vs benchmark for various intervals including since-inception, year-to-date and latest month. Fidelity provides a Statement for every client account every month. The Statement provides beginning and ending market value and a complete transaction history for the month. Fidelity provides all necessary tax documents as well: Form 1099 for taxable accounts, Form 1099R for retirement accounts if distributions have been paid and Form 5498 if contributions have been made. For employer-sponsored qualified retirement plans, Cape Ann Capital provides monthly performance reports to supplement the valuation and position reports provided by recordkeepers. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Incoming Referrals Cape Ann Capital does not pay anyone for referral business. Referrals Out Cape Ann Capital does not receive any income for referring business to anyone. Other Compensation Cape Ann Capital’s only compensation are the fees cited in Item 5 of this brochure. Cape Ann Capital does not have any arrangements under which we receive any economic benefit, including sales awards or prizes. Firm Brochure–Part 2A of Form ADV 13 December 31, 2025  ITEM 15: CUSTODY Cape Ann Capital does not have custody of client assets. Most Cape Ann Capital clients use Fidelity as their primary custodian. A few clients have additional assets that we manage that are custodied at other custodians such as TIAA-CREF, J.P. Morgan Retirement Plan Services and Vanguard. ITEM 16: INVESTMENT DISCRETION Cape Ann Capital has full investment discretion over nearly 99% of its client accounts, and about 94% of its AUM. Nearly all clients have given Cape Ann Capital limited power of attorney to trade on their behalf. Despite having discretionary authority, we are more than willing to discuss pending transactions in advance if desired by the client. Once each client gives us a long-term asset target, the client can be as involved or uninvolved as they wish in our investment process. Typically, if a transaction generates meaningful taxable income we will ask for client approval before making the trade. ITEM 17: VOTING CLIENT SECURITIES If a client so desires, Cape Ann Capital will accept the authority to vote proxies on their behalf. Proxy Votes Cape Ann Capital’s written Proxy Voting Policy is available upon request. As Cape Ann Capital’s clients generally invest in mutual funds and exchange traded index funds rather than directly in securities, this issue is not of the same importance that it otherwise would be. Our objective in voting proxies is to support proposals and director nominees that maximize the expected long-term value of client investments. Proxy proposals are varied and complex. As such, Cape Ann Capital’s Proxy Voting Policy guidelines can only provide a framework for assessing each proposal. The Policy stresses Cape Ann Capital’s role as a fiduciary with responsibility for evaluating each proposal on its merits, based on facts and circumstances as presented. Cape Ann Capital gives substantial weight to the recommendations of the company’s board, absent other specific facts that would support a vote against management. ITEM 18: FINANCIAL INFORMATION Since Cape Ann Capital invoices its fees in arrears, it is not required to include a balance sheet for its most recent fiscal year. ITEM 19: REQUIREMENTS FOR STATE-REGISTERED ADVISERS Cape Ann Capital is an SEC registered adviser and not a state-registered adviser. Firm Brochure–Part 2A of Form ADV 14 December 31, 2025  Additional information about Jeremy DiStefano is available on the SEC’s website at www.adviserinfo.sec.gov FIRM BROCHURE SUPPLEMENT (PART 2B OF FORM ADV) Cape Ann Capital, Inc. 22 Grove Street Concord, MA 01742 (978) 254-5841 (O) (978) 816-9531 (C) (978) 254-5461 (F) www.capeanncapital.com jimj@capeanncapital.com December 31, 2025 Jeremy M. DiStefano Cape Ann Capital, Inc. 205 Willow St South Hamilton, MA 01982 (617) 548-1755 (O/C) jeremyd@capeanncapital.com This brochure supplement provides information about Jeremy M. DiStefano, Managing Principal of Cape Ann Capital, Inc. This information supplements Cape Ann Capital’s brochure. The brochure and supplements are available at Cape Ann Capital’s website … www.capeanncapital.com. Please contact Jeremy DiStefano, Managing Principal and Chief Compliance Officer if you have questions about the contents of this supplement. !FIN-Form ADV-Part 2B Jeremy DiStefano Dec2025.doc1 December 31, 2025  ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS Jeremy M. DiStefano, CFA Year of Birth: 1979 Formal Education after High School BS Computer Information Systems, Bentley University, 2001 income investments, derivatives, alternative The Chartered Financial Analyst (CFA) designation is awarded to those who successfully complete a graduate-level self-study program that combines a broad curriculum culminating in three sequential exams. The CFA curriculum includes ethical and professional standards, quantitative methods, economics, financial reporting and analysis, corporate finance, equity investments, portfolio fixed investments, management and wealth planning. Business Background Senior Coordinator, Financial Architects Partners, 2005-2007 Assistant Vice President, Income Research + Management, 2007-2014 Senior Analyst, Client Services, Lightkeeper, LLC, 2015-2016 Portfolio Manager, Cape Ann Capital, Inc., 2016-present ITEM 3: DISCIPLINARY INFORMATION There are no legal or disciplinary events to report regarding Mr. DiStefano. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. DiStefano is not actively engaged in any investment-related business or occupation other than Cape Ann Capital (for example, activities that pertain to securities, commodities, banking, insurance, or real estate). Mr. DiStefano is not registered, nor does he have an application pending to register, as a broker-dealer, registered representative or broker-dealer, futures commission merchant, commodity pool operator or commodity trading advisor. Mr. DiStefano is not an associated person of a futures commission merchant, commodity pool operator or commodity trading advisor. !FIN-Form ADV-Part 2B Jeremy DiStefano Dec2025.doc2 December 31, 2025  ITEM 5: ADDITIONAL COMPENSATION Mr. DiStefano receives no arrangements in which someone other than a client gives Mr. DiStefano an economic benefit, such as a sales award or other prize, for providing advisory services. ITEM 6: SUPERVISION As Managing Principal and Chief Compliance Officer, Mr. DiStefano is responsible for software systems and procedures to ensure that all portfolios are managed in compliance with their guidelines, as well as supervision, formulation and monitoring of investment advice to clients. Mr. DiStefano may be contacted at (617) 548-1755. As Managing Principal, Mr. Jasinski is responsible for the company’s long-term business strategies and client communications, as well as supervision, formulation and monitoring of investment advice to clients. Mr. Jasinski is an investment advisor representative. He may be contacted at (978) 254-5841. Messieurs Jasinski and DiStefano monitor every client portfolio and every mutual fund on the Cape Ann Capital Buy List daily. If a portfolio or a fund displays an unusual performance pattern they investigate. Cape Ann Capital does not have custody of client assets but maintains a duplicate copy of client position and transactions records. Messieurs Jasinski and DiStefano use this information for performance measurement and reporting purposes. For those custodians that provide electronic downloading capabilities, Messieurs Jasinski and DiStefano reconcile positions daily. Where electronic communication is not available, they reconcile every month-end. Messieurs Jasinski and DiStefano provide a written Portfolio Review to every client every month. The Review contains commentary on the markets and provides snapshots of month- end holdings, recent fees and performance for the portfolio and its benchmark. The Cape Ann Capital Buy List is derived from a statistical analysis of every mutual fund in the country. Messieurs Jasinski and DiStefano periodically review this research to maintain a Buy List containing only the most skillfully managed mutual funds. Every Cape Ann Capital portfolio is unique. Each client selects a long-term asset allocation target and Messieurs Jasinski and DiStefano create a portfolio optimized from the Cape Ann Capital Buy List to best meet this target. They periodically review all client portfolios and rebalance any holdings that have drifted away from the optimized target. ITEM 7: REQUIREMENTS FOR STATE-REGISTERED ADVISERS This is not required as Cape Ann Capital is a federally registered investment adviser. !FIN-Form ADV-Part 2B Jeremy DiStefano Dec2025.doc3 December 31, 2025  Additional information about James J. Jasinski is available on the SEC’s website at www.adviserinfo.sec.gov FIRM BROCHURE SUPPLEMENT (PART 2B OF FORM ADV) Cape Ann Capital, Inc. 22 Grove Street Concord, MA 01742 (978) 254-5841 (O) (978) 816-9531 (C) (978) 254-5461 (F) www.capeanncapital.com jimj@capeanncapital.com James R. Jasinski Cape Ann Capital, Inc. 22 Grove St Concord, MA 01742 (978) 254-5841 (O) (617) 816-9531 (C) (978) 254-5461 (F) jimj@capeanncapital.com This brochure supplement provides information about James R. Jasinski, Managing Principal of Cape Ann Capital, Inc. This information supplements Cape Ann Capital’s brochure. The brochure and supplements are available at Cape Ann Capital’s website … www.capeanncapital.com. Please contact Jeremy DiStefano, Managing Principal and Chief Compliance Officer at (617) 548-1755 if you have questions about the contents of this supplement. !FIN-Form ADV-Part 2B James Jasinski Dec2025.doc 1 December 31, 2025  ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS James R. Jasinski, CMT, CFP® Year of Birth: 1970 Formal Education after High School BA United States History, Williams College, 1993 The Chartered Market Technician (CMT) designation is awarded to those who successfully complete three sequential exams. The CMT curriculum focuses on six knowledge domains of technical analysis: General Principles; Trend and Momentum; Sentiment (Behavioral Finance); Inter-market Analysis; and Trading Investment Strategies. Candidates must also pass an Ethics component on each exam. Financial Planning, Boston University, 2011 The CERTIFIED FINANCIAL PLANNER™ (CFP®) designation is awarded to those who successfully complete an educational component and meet work experience requirements. Candidates must also complete an exam focused across the knowledge domains of Financial Planning: General Principles of Financial Planning, Insurance Planning and Risk Management, Employee Benefits Training, Investment Planning, Income Tax Planning, Retirement Planning and Estate Planning. Business Background Team Leader, John Hancock Funds, 1994-1996 Sales Trader, Jones and Associates, LLC, 1996-1999 VP Sales Trading, Adams, Harkness and Hill, 1999-2003 Principal Sales Trading, America's Growth Capital, 2003-2005 Director Sales Trading, Avondale Partners, LLC, 2005-2007 Financial Advisor, UBS Financial Services, 2007-2009 VP Investment Advisor, Cape Ann Capital, Inc., 2009-2013 Chief Executive Officer, Cape Ann Capital, Inc., 2013-2016 !FIN-Form ADV-Part 2B James Jasinski Dec2025.doc 2 December 31, 2025  Managing Principal, Cape Ann Capital, Inc., 2016 - present ITEM 3: DISCIPLINARY INFORMATION There are no legal or disciplinary events to report regarding Mr. Jasinski. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Jasinski is not actively engaged in any investment-related business or occupation other than Cape Ann Capital (for example, activities that pertain to securities, commodities, banking, insurance, or real estate). Mr. Jasinski is not registered, nor does he have an application pending to register, as a broker-dealer, registered representative or broker-dealer, futures commission merchant, commodity pool operator or commodity trading advisor. Mr. Jasinski is not an associated person of a futures commission merchant, commodity pool operator or commodity trading advisor. ITEM 5: ADDITIONAL COMPENSATION Mr. Jasinski receives no arrangements in which someone other than a client gives Mr. Jasinski an economic benefit, such as a sales award or other prize, for providing advisory services. ITEM 6: SUPERVISION As Managing Principal, Mr. Jasinski is responsible for the company’s long-term business strategies and client communications, as well as supervision, formulation and monitoring of investment advice to clients. Mr. Jasinski is an investment advisor representative. He may be contacted at (978) 254-5841. As Managing Principal and Chief Compliance Officer, Mr. DiStefano is responsible for software systems and procedures to ensure that all portfolios are managed in compliance with their guidelines, as well as supervision, formulation and monitoring of investment advice to clients. Mr. DiStefano may be contacted at (617) 548-1755. Messieurs Jasinski and DiStefano monitor every client portfolio and every mutual fund on the Cape Ann Capital Buy List daily. If a portfolio or a fund displays an unusual performance pattern they investigate. Cape Ann Capital does not have custody of client assets but maintains a duplicate copy of client position and transactions records. Messieurs Jasinski and DiStefano use this information for performance measurement and reporting purposes. For those custodians that provide electronic downloading capabilities, Messieurs Jasinski and DiStefano reconcile positions daily. Where electronic communication is not available, they reconcile every month-end. !FIN-Form ADV-Part 2B James Jasinski Dec2025.doc 3 December 31, 2025  Messieurs Jasinski and DiStefano provide a written Portfolio Review to every client every month. The Review contains commentary on the markets and provides snapshots of month- end holdings, recent fees and performance for the portfolio and its benchmark. The Cape Ann Capital Buy List is derived from a statistical analysis of every mutual fund in the country. Messieurs Jasinski and DiStefano periodically review this research to maintain a Buy List containing only the most skillfully managed mutual funds. Every Cape Ann Capital portfolio is unique. Each client selects a long-term asset allocation target and Messieurs Jasinski and DiStefano create a portfolio optimized from the Cape Ann Capital Buy List to best meet this target. They periodically review all client portfolios and rebalance any holdings that have drifted away from the optimized target. ITEM 7: REQUIREMENTS FOR STATE-REGISTERED ADVISERS This is not required as Cape Ann Capital is a federally registered investment adviser. !FIN-Form ADV-Part 2B James Jasinski Dec2025.doc 4 December 31, 2025