ELLSWORTH ADVISORS, LLC

Item 1: Cover Page This Firm Brochure (Form ADV Part 2A) provides information about the qualifications and business practices of Ellsworth Advisors, LLC. Please contact Michelle Schwab, Chief Compliance Officer if you have any questions about the contents of this brochure. 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 Ellsworth Advisors, LLC is also available on the SEC’s website at www.advisorinfo.sec.gov. Ellsworth Advisors, LLC’s CRD number is: 297464. Investing in individual stocks, mutual funds, fixed income securities, insurance products (including annuities), hedge funds, alternative investments, ETFs (including ETFs in the gold and precious metal sectors), non-U.S. securities, venture capital funds and alternative investments have the potential for loss of all invested dollars. Registration does not imply a certain level of skill or training. CUSTODIAN INFORMATION: CHARLES SCHWAB & CO., INC. 3000 SCHWAB WAY WESTLAKE, TEXAS 76262 PHONE: 800.435.4000 WEBSITE: WWW.SCHWAB.COM ADVISOR INFORMATION: ELLSWORTH ADVISORS, LLC ATTN: MICHELLE M. SCHWAB, CHIEF COMPLIANCE OFFICER 1764 GEORGETOWN ROAD HUDSON, OHIO 44236 PHONE: 234.901.2831 FACSIMILE: 234.252.2461 EMAIL: MSCHWAB@ELLSWORTHADVISORS.COM 1 | P a g e February 2026  Item 2: Material Changes There have been no material changes to this brochure since March 2024. Material changes relate to Ellsworth Advisors, LLC’s policies, practices, or conflicts of interests. 2 | P a g e February 2026  Item 3: Table of Contents Table of Contents Item 1: Cover Page................................................................................................................................................... 1 Item 2: Material Changes ........................................................................................................................................ 2 Item 4: Advisory Business ....................................................................................................................................... 5 A. Description of the Advisory Firm............................................................................................................... 5 B. Types of Advisory Services ........................................................................................................................ 5 C. Client Tailored Services and Client Imposed Restrictions ....................................................................... 10 D. Wrap Fee Programs ................................................................................................................................. 10 E. Assets Under Management..................................................................................................................... 11 Item 5: Fees and Compensation ............................................................................................................................ 12 A. Fee Billing ................................................................................................................................................ 12 B. Payment of Fees ...................................................................................................................................... 14 C. Additional Fees and Charges ................................................................................................................... 15 D. Prepayment of Fees ................................................................................................................................ 15 E. Outside Compensation for the Sale of Securities to Clients ................................................................... 16 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................ 17 Item 7: Types of Clients ......................................................................................................................................... 17 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ..................................................................... 18 A. Methods of Analysis and Investment Strategies ..................................................................................... 18 B. Material Risks Involved ........................................................................................................................... 19 C. Risks of Specific Securities Utilized .............................................................................................................. 20 Item 9: Disciplinary Information........................................................................................................................... 24 A. Disciplinary Information .......................................................................................................................... 24 B. Administrative Proceedings .................................................................................................................... 24 C. Self-Regulatory Organization (SRO) Proceedings .................................................................................... 24 Item 10: Other Financial Industry Activities and Affiliations ................................................................................ 25 A. Registration as a Broker/Dealer or Broker/Dealer Representative......................................................... 25 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor .................................................................................................................................................... 25 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ......... 25 D. Selection of Other Advisors or Managers and How This Advisor is Compensated for Those Selections 25 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 27 3 | P a g e February 2026  A. Code of Ethics.......................................................................................................................................... 27 B. Recommendations Involving Material Financial Interests ...................................................................... 27 C. Investing Personal Money in the Same Securities as Clients .................................................................. 28 D. Trading Securities At/Around the Same Time as Client’s Securities ....................................................... 28 Item 12: Brokerage Practices ............................................................................................................................... 29 A. The Custodians and Brokers We Use ...................................................................................................... 29 B. How We Select the Custodians and Brokers We Use ............................................................................. 29 C. Your Custody and Brokerage Costs ......................................................................................................... 30 D. Products and Services Available to Us.......................................................................................................... 30 E. Aggregating (Block) Trading for Multiple Client Accounts ...................................................................... 32 Item 13: Review of Accounts ................................................................................................................................ 33 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ........................................ 33 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ...................................................... 33 C. Content and Frequency of Regular Reports Provided to Clients............................................................. 33 Item 14: Client Referrals and Other Compensation ............................................................................................. 34 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ........................................................................................................................................... 34 Economic Benefits Provided to Us from Charles Schwab & Co., Inc.(“Schwab”) ............................................... 34 B. Compensation to Non – Advisory Personnel for Client Referrals ........................................................... 34 Item 15: Custody .................................................................................................................................................. 35 A. Retail Accounts ....................................................................................................................................... 35 B. Alternative Investments .......................................................................................................................... 35 Item 16: Investment Discretion ............................................................................................................................. 36 Item 17: Voting Client Securities (Proxy Voting) ................................................................................................... 37 Item 18: Financial Information .............................................................................................................................. 37 A. Balance Sheet .......................................................................................................................................... 37 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients 37 C. Bankruptcy Petitions in Previous Ten Years ............................................................................................ 37 4 | P a g e February 2026  Item 4: Advisory Business Ellsworth Advisors, LLC (“Advisor”) offers the following services to advisory clients (“Client”): A. Description of the Advisory Firm Ellsworth Advisors, LLC (“Advisor”) is a Limited Liability Company organized in the State of Ohio. The firm was formed in March 2018, and the principal owner is Ellsworth Advisors Holdings, LLC which is solely owned by Ellsworth Advisors Holdings, LLC. Advisor is a large Registered Investment Advisor and Institutional Investment Manager registered with United States Securities and Exchange Commission. Our 16-member team has over 100 years of combined investment experience. With backgrounds in accounting, banking, broker/dealers, insurance, investment banking, and private equity. We have also earned several industry recognized certifications: CERTIFIED FINANCIAL PLANNER™ Certified Plan Fiduciary Advisor Chartered Retirement Planning CounselorSM B. Types of Advisory Services Individual Wealth Management Advisor offers ongoing individual wealth management services, also known as portfolio management, based on the individual goals, objectives, time horizon, and risk tolerance of each client. Advisor completes an Investment Policy Statement for each client or household, which outlines the client’s current situation (investment objectives, risk tolerance, investment experience, short- and long-term liquidity needs, net worth, and income). Advisor evaluates the investments of each client with respect to their Investment Policy Statement. Individual wealth management services include, but are not limited to, the following: Investment Policy Statement creation • • Assessing risk tolerance • Investment strategy allocation • Comprehensive financial strategy • Asset management and allocation • Retirement and estate planning • Continuous access to financial advisors and portfolio manager • Monthly performance reporting • Monthly economic and market activity discussion • Cash management for identified liquidity needs • Professional opinions on the management of accounts held elsewhere Advisor will request discretionary authority from most clients to select securities and execute transactions without permission from the client prior to each transaction. 5 | P a g e February 2026  Advisor’s investment decisions are made in accordance with the fiduciary duties owed to our clients and without consideration of Advisor’s economic, investment or other financial interests. To meet its fiduciary obligations, Advisor attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Advisor’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Advisor’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time of those who are eligible and interested. Advisor has discretion to choose third-party investment advisors to manage all or a portion of the client’s assets. These investments may be allocated either through the third-party advisor’s fund or through a separately managed account managed by such third-party advisor on behalf of Advisor’s client. Advisor may also allocate among one or more private equity funds or private equity fund advisors. Before selecting other advisors for clients, Advisor will ensure those other advisors are properly licensed or registered as an investment advisor. Advisor conducts due diligence on any third-party investment advisor, which may involve one or more of the following: phone calls, references, meetings, disclosures including disciplinary actions and review of the third-party advisor’s organization, performance, and investment strategy. Advisor will review the ongoing performance of the third-party advisor(s) as a portion of the client’s portfolio. Advisor generally limits its investment advice to individual stocks, mutual funds, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), and private placements. Although Advisor primarily recommends publicly traded securities, Advisor may use other securities as well to help diversify a portfolio when applicable. Corporate Retirement Plans Advisor offers pension consulting services to pensions and other employee benefit plans (including but not limited to 401(k) plans). Retirement plan sponsors of an employee plan may hire an outside advisor to defer the fiduciary duties of managing the investments inside the pension or employee benefits plan. The outside advisor can provide services under sections 3(21) or3(38) of the Employee Retirement Income Security Act of 1974. A 3(21) Advisor renders investment advice on a regular basis for compensation; discretionary authority over management or disposition of assets; known as investment “advisor”; advisor makes recommendations; committee decides & retains responsibility for outcomes. A 3(38) Manager must acknowledge status in writing; must be RIA, bank or insurance company; known as investment “manager”; committee grants discretionary authority to manage assets; manager provides asset management for committee; liability shifts from committee to manager; Committee retains liability for selection & monitoring of manager, including reasonableness of fees. 6 | P a g e February 2026  Pension consulting may include any of the following: Investment advisory services • • Creating an Investment Policy Statement • Discretionary investment changes (3(38)) plans), • Ongoing investment recommendations (3(21) plans), • Ongoing investment monitoring, • Qualified default investment alternative assistance (“QDIA”), • Discretionary model portfolios (3(38)) plans), • Non-Discretionary model portfolios (3(21) plans), • Performance reports, • Consulting services, • Service provider liaison, • Education services to Plan Committee, • Participant enrollment, • Participant education, • Plan search support/vendor analysis, • Benchmarking services, and • Assistance identifying Plan fees These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Advisor generally limits its investment advice to individual stocks, mutual funds, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), and private placements. Although Advisor primarily recommends publicly traded securities, Advisor may use other securities as well to help diversify a portfolio when applicable. Retirement Accounts Guidance from the US Department of Labor (DOL) under Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code (Code), requires Advisor to remind Clients that when we provide investment advice (including recommendations of our advisory program(s)) regarding ERISA retirement plans or participant accounts or individual retirement accounts (which are all referred to as “retirement accounts”), that the Advisor is a fiduciary 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. Regulations under ERISA and the Code define fiduciary investment advice as (1) advice or recommendations, for a fee or other compensation, regarding investing in, purchasing or selling securities or other property to a plan, plan participant, or IRA owner; (2) provided on a regular basis; (3) where the advice is provided pursuant to a mutual agreement or understanding; (4) the advice serves as a primary basis for investment decisions with respect to the plan or IRA assets; and (5) the advice is individualized to the plan, participant or IRA owner. 7 | P a g e February 2026  Retirement Plan Rollovers When leaving an employer, Clients typically have four options regarding the existing retirement plan: (1) leave the assets in the former employer’s plan, if permitted, (2) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (3) roll over the assets to an Individual Retirement Account (“IRA”), or (4) take a full withdrawal in cash, which would result in ordinary income tax and a penalty tax if you are under age 59 1/2. If Advisor recommends that a Client roll over a 401(k) or other qualified plan assets to an IRA, this roll over recommendation presents a conflict of interest in that Advisor would receive compensation (or may increase current compensation) when investment advice is provided following the decision to roll over plan assets. Advisor will discuss retirement plan options including retention of 401(k) or qualified plan assets with the current plan, if allowed. Prior to deciding Client should carefully review the information regarding roll over options and are under no obligation to roll over retirement plan assets to an account managed by Advisor. If an advisory account is subject to the provisions of ERISA or certain tax deferred treatment under the Internal Revenue Code (collectively, “Qualified Accounts”) Advisor is generally prohibited from receiving both an advisory fee and any transaction-based compensation unless in compliance with applicable prohibited transaction exemptions under ERISA or the IRC or authorized by the U.S. Department of Labor. Best efforts will be made to collect information about the Plan. Including a search of publicly available Form 5500 and Plan documents, including any investment policies, guidelines, or restrictions that Client may provide. Financial Consulting Financial consulting, also known as financial planning services, includes financial plan development, estate planning, tax advice, business valuations and advising on mergers or acquisitions for our business clients. Financial plans are available to all clients via a third-party vendor (eMoney Advisor, LLC) that can generate on-demand financial plans. The client is responsible for establishing the data feeds into the system and providing any additional information they would like to see reflected in their plan. A more in-depth personal financial plan can be created with the execution of a Financial Planning Agreement. A personal financial plan will typically include: • investment planning; • life insurance; • tax concerns; • retirement planning; • college planning; and • debt/credit planning. 8 | P a g e February 2026  Estate Planning Generally, estate planning is the process of designating who will receive your assets at your death and handle your responsibilities if you are not able to do so. Estate planning services offered by Advisor are in conjunction with an estate attorney that specializes in the creation of trusts, medical care directives, wills, powers of attorney, etc. Advisor does not prepare trusts, medical care directives, wills, powers of attorney, etc. Tax Advice Tax advice provided by Advisor is limited to making recommendations on what types of accounts to open, whether a position has short- or long-term tax consequences, and the impact of all the accounts held by the client could have on their individual federal and state tax tables. Clients should always consult with a tax professional for specific advice to their unique situation. Advisor does not prepare tax returns. Business Valuation Business valuation is the process of determining the economic value of a business or division. Business valuations can be used to determine the fair value of a business. Advisor’s team includes individuals with a background in investment banking. With this background, in conjunction with a qualified tax professional, we can help you evaluate your business for a potential sale, establishing partner ownership, etc. Merger and Acquisitions Merger and acquisitions advisory services primarily focus on the current industry environment, business valuation, and possible credit opportunities. Alternative Investing In addition to traditional wealth management, Advisor also offers access to private equity and private real estate investments. These private investments, as part of a well-diversified portfolio, can offer diversification non-correlated to the public markets. These investments are offered on a deal-by-deal basis and are not invested on a discretionary basis. Typically, these investments will only be available to accredited investors as defined by Rule 501(a), Rule 215, and Rule 144A of the Securities Act. Family Office Services A family office provides a wider range of services tailored to meet the needs of high-net-worth individuals. Advisor can provide the following services for family offices: • Entity formation; • Office management and oversight; • Investment analysis; • Financial reporting; • Charitable giving advice; • Concierge services. 9 | P a g e February 2026  C. Client Tailored Services and Client Imposed Restrictions Advisor will tailor a portfolio for the needs of each client. This will include an interview session to create an Investment Policy Statement. Advisor will create a portfolio using one to five strategies and individual positions. This combination is based on the Clients Investment Policy Statement. Clients may impose reasonable restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Advisor from properly servicing the client account, or if the restrictions would require Advisor to deviate from its standard suite of services, Advisor reserves the right to end the relationship. D. Wrap Fee Programs Advisor acts as portfolio manager for and sponsor of wrap fee programs, which is an investment program where the client pays a negotiable fee. A. Discretionary Trading Authorization (“Advisory Wrap Fee Program”) - Client grants Advisor discretionary trading authorization, with respect to the purchase and sale of securities in Client’s Managed Account. Advisor will direct, in Advisor’s sole discretion and without first consulting Client, the purchase and/or sale of securities on a discretionary basis within the Client’s Managed Account. Client hereby agrees to execute all documents required by Advisor and/or Custodian to establish both the Managed Account and the discretionary trading authorization including fee deductions. B. Discretionary Sub-Advisor Authorization (“Sub-Advised Wrap Fee Program”) - Client grants Advisor discretionary authorization to select, change, or terminate a Sub-Advisor on behalf of Client. Client hereby agrees to execute all documents required by Advisor and/or Sub- Advisor to establish the Sub-Advisor Account. Client will be notified thirty (30) calendar days prior to the hire, change, or termination of a Sub-Advisor. Such notification will include the Sub-Advisor’s ADV, and management fees charged by Sub- Advisor. C. Non-Discretionary Trading Authorization (“Non-Advisory Wrap Fee Program”) – Client grants Advisor trading authorization with respect to the purchase and sale of securities in Client’s Managed Account. Client will direct the purchase and/or sale of securities within the Client’s Managed Account. Client hereby agrees to execute all documents required by Advisor and/or Custodian to establish both the Managed Account and the trading authorization including fee deductions. This brochure describes Advisor’s Non-Advisory Wrap Fee Program; clients utilizing Advisor’s Advisory Wrap Fee Program or Sub-Advised Wrap Fee Program should see the separate Form ADV Part 2A Appendix 1 (Wrap Fee Program Brochure). All of the fees collected are kept by Advisor as the portfolio manager and program sponsor. 10 | P a g e February 2026  E. Assets Under Management Advisor has the following assets under management: Discretionary Amounts: $837,670,296 Pension Consulting Services 3(38): Date Calculated: December 2025 $554,274,624 Advisor has the following assets under advisement: Non-Discretionary Amounts: $2,609,485 Pension Consulting Services 3(21): Date Calculated: December 2025 $11,910,175 11 | P a g e February 2026  Item 5: Fees and Compensation A. Fee Billing Billing of Individual Wealth Management Services Fees Total Assets Under Management All Assets Annual Fees 1.00% Advisory Fees are negotiable depending upon the needs of the Client and the complexity of the situation. To calculate the monthly fees, Advisor uses the average daily balance in the client's account throughout the billing period for purposes of determining the market value of the assets. This market value is used to calculate the monthly fees by multiplying the average daily balance by the negotiated fee. This value is then multiplied by the number of days in the month divided by the number of days in the year. Advisor charges a single asset-based fee for services covered by the wrap program. The maximum fee charged for the program is 1.00%. ((Average daily balance market value) x (negotiated annual fee)) X ((days in the billing month) / (days in the year)) Example: $100,000 * .01 = $1,000 30 days / 365 = .082 $1,000 * .082 = $82.19 for the monthly fee With the client’s written permission, Advisor deducts fees directly from the client’s account(s). Fees are deducted monthly and in arrears. All of the fees collected are kept by Advisor as the portfolio manager. Advisor reserves the right to amend its fee schedule at any time upon thirty (30) days written notice to Client. 12 | P a g e February 2026  Billing of Corporate Retirement Plan Fees Advisor is compensated for its Corporate Retirement Plans via a fee schedule that is documented in Schedule A of the Retirement Plan Consulting Program agreement. Advisor and the client may agree to a fixed annual, quarterly, or monthly amount. The standard rate for fixed fees is between $2,500 and $150,000 annually. The final fee schedule will be memorialized in the Retirement Plan Consulting Program agreement Schedule A. Advisor and the client may agree to a fee based on a percentage of assets under advisement. Fees are negotiable and can be charged on a percentage of assets under advisement, a per participant fee, a fixed fee, or a combination of fee options. For example, there can be a flat quarterly fee in combination with a per participant fee. When the fee is based on the assets under advisement, the percentage of assets under advisement advisory fee is calculated based on the average daily balances in the client's account throughout the billing period. Per participant fees will be based on the number of participants enrolled in the plan. The final fee schedule will be memorialized in the Retirement Plan Consulting Program agreement Schedule A. Billing of Financial Consulting Fees Advisor is compensated for Financial Consulting. A fixed rate for creating client financial plans is negotiable and based on numerous factors such as complexity, number of accounts, tax considerations, distribution calculations, various account types, and current investments to name a I. few and is memorialized in the Financial Planning Agreement Exhibit These fees are charged in arrears upon completion. If the Financial Planning Agreement is terminated prior to completion of the financial planning services, then Client will be responsible for paying the prorated fee for work completed but unpaid (if any) at the time termination becomes effective. Billing of Alternative Investing Fees Private Equity and Private Real Estate Advisor is not compensated for offering alternative investments although there are costs associated with these types of investments. The costs associated with each alternative investment will be detailed in the documentation provided by the investment bank or sponsor. Variable and Fixed Annuities Advisor will be compensated by the insurance company for annuities that the Advisor is an agent or broker for. These fees are referred to as commissions and will be taken from your initial and/or ongoing investment. The costs associated with each annuity will be detailed in the prospectus delivered by the offering insurance company. Billing of Family Office Services Fees The costs associated with the creation of the Family Office would be borne by the family creating the office. 13 | P a g e February 2026  B. Payment of Fees Payment of Individual Wealth Management Services Fees With the Client’s written permission, Advisor deducts fees directly from the Client’s Managed Account(s). Fees are deducted monthly and in arrears. Payment of Corporate Retirement Plan Fees Fixed pension consulting fees are paid via check or wire. These fees are paid in arrears upon completion. With the client’s written permission, fees can be withdrawn directly from the client's accounts on a monthly or quarterly basis. Fees are paid in arrears. Payment of Financial Consulting Fees The fixed financial consulting fees are paid via check or wire. Depending on the complexity, a deposit may be required at the time the agreement is executed; however, the balance will be paid in arrears upon completion. Payment of Alternative Investing Fees Private Equity and Private Real Estate Advisor is not compensated for offering alternative investments although there are costs associated with these types of investments. The costs associated with each alternative investment will be detailed in the documentation provided by the investment bank or sponsor. Variable and Fixed Annuities Advisor will be compensated by the insurance company for annuities that the Advisor is an agent or broker for. These fees are referred to as commissions and will be taken from your initial and/or ongoing investment. The costs associated with each annuity will be detailed in the prospectus delivered by the offering insurance company. Payment of Family Office Services Fees The costs associated with creation of a family office are paid via check or wire. 14 | P a g e February 2026  C. Additional Fees and Charges Client understands that additional fees or charges may result from maintenance of, or trading within, the Managed Account. Client understands and agrees that any additional fees, charges, or expenses resulting from maintenance of, or trading within, the Managed Account not covered by the wrap fee shall be the sole responsibility of the Client. Advisor’s wrap fee does not include the fees and costs listed below. The fees and costs may apply to transactions in your account. The fees and costs not included in the wrap fee that you will pay include: • Commissions and other fees charged by broker-dealers other than Schwab for transactions in your account if Advisor uses Schwab’s Prime Brokerage, Step-In, or Trade Away Services. Because you will pay our wrap fee in addition to any charges paid to broker- dealers other than Schwab, we have an incentive to execute transactions for your account through Schwab. • Fees charged by mutual fund companies, closed-end funds, electronically traded funds, and other collective investment vehicles, including, but not limited to, sales loads and/or charges and short-term redemption fees. • Markups and markdowns, bid-ask spreads, and selling concessions in connection with transactions Schwab executes as principal. Principal transactions contrast with transactions in which Schwab acts as your agent in affecting trades. Markups and markdowns and bid-ask spreads are not separate fees but are reflected in the net price at which a trade order is executed. • Costs imposed by third parties, such as transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, and any other fees required by law. Schwab may also charge for additional services such wire transfer fees and fees for alternative investments. • Taxes on brokerage accounts and securities transactions. These fees and expenses are collected by Custodian, Charles Schwab & Co., Inc. (“Schwab”), and are not paid to Advisor. D. Prepayment of Fees Advisor collects its fees in arrears. It does not collect fees in advance. 15 | P a g e February 2026  E. Outside Compensation for the Sale of Securities to Clients Christopher Ameen, Brett Baskin, Kelly Kuennen, and Michael “Max” Schindler are insurance agents. In these roles, they may accept compensation for the sale of insurance products to Advisor clients. This is a Conflict of Interest Insurance agents (also known as supervised persons) may accept compensation for the sale of investment products, including commissions from the sale of insurance products to Advisor's clients. This conflict of interest is mitigated in that clients are not required to invest in such investments if they do not wish to do so. These products are not included in the discretionary authority granted by clients. Additionally, Advisor always acts in the best interest of the client consistent with its fiduciary duties. This conflict is disclosed to clients in the Wrap Fee Program Brochure and in the Form ADV Part 2Bs. Both disclosures are provided to the client prior or at the time the Investment Management Agreement is signed. Clients Have the Option to Purchase Recommended Products from Other Brokers Clients always have the option to purchase Advisor recommended products through other brokers or agents that are not affiliated with Advisor. Cameron Miele offers private equity opportunities through his commercial fishing business outside business activities. Cameron and his partner collect a promotional fee for this investment. The promotional fee is paid in the form of an additional percentage of dividends paid from the private equity. Advisor does not receive any of these promotional fees. This is a Conflict of Interest This is a conflict of interest because the amount of the promotional fee will be based on the amount of dividends paid which is based, in part, on the total amount invested by outside investors. This conflict cannot be mitigated but will be detailed in the agreements provided to accredited investors at the time of purchase. 16 | P a g e February 2026  Item 6: Performance-Based Fees and Side-By-Side Management Advisor 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 Advisor generally provides advisory services to the following types of clients: Individuals • • High-Net-Worth Individuals • Corporations or Other Businesses • Pension and Profit-Sharing Plans • Trusts There is no account minimum for any of Advisor’s services. 17 | P a g e February 2026  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss Investing in securities involves a risk of total loss. You as the client should only invest what you can afford to lose. The risk of loss is entirely yours, the client, as an investor in securities. A. Methods of Analysis and Investment Strategies Methods of Analysis Advisor’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. Advisor uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data, primarily price and volume. Investment Strategies Advisor uses long term and short-term trading strategies. Publicly traded equities are primarily used with most non-accredited retail clients. Investments in options or e-currency is not an investment strategy currently used by Advisor. 18 | P a g e February 2026  B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing patterns in performance charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be assuming that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will not be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis investment strategies using quantitative models may perform differently than expected because of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not consider new patterns that emerge over time. 19 | P a g e February 2026  Investment Strategies Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short-term trading risks include liquidity, economic stability, and inflation, in addition to the long- term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Although Advisor will seek to select only money managers who will invest clients' assets with the highest level of integrity, Advisor's selection process cannot ensure that money managers will perform as desired, and Advisor will have no control over the day-to-day operations of any of its selected money managers. Advisor would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Although Advisor does not normally invest in option transactions, it is important for our clients to understand the risk associated with them. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. The prices of securities held in client accounts and the income they generate may decline in response to certain events taking place around the world. These include events directly involving the issuers of securities held as underlying assets of funds in a client’s account, conditions affecting the general economy, and overall market changes. Other contributing factors include local, regional, or global political, social, or economic instability and governmental or governmental agency responses to economic conditions. Finally, currency, interest rate, and commodity price fluctuations may also affect security prices and income. A brief description of the types of securities that Advisor will invest (non-accredited investor) in are listed below. These securities are listed in the order of the percentage they make up of our strategies. Exchange-Traded Equity Securities: Equity securities generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. 20 | P a g e February 2026  U.S. State and Local Bonds: Bonds generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment is made up of government debt securities. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer- term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. Issued by Registered Investment Companies (“RIC”) or Business Development Securities Companies(“BDC”): In our strategies, these securities are mostly in the form of: Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, like stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Cash and Cash Equivalents: Cash and cash equivalents (money market funds) are highly liquid assets that include cash and short-term investments that are easily convertible to cash. Cash carries inflation risk. A brief description of additional types of securities the Advisor will invest accredited investor dollars in are listed below. These securities are listed in the order of the percentage they make up of our strategies/portfolios. U.S. Government/Agency Bonds: The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Securities Issued by Pooled Investment Vehicles (other than RICs and BDCs): These types of investments are typically annuities, commodities, and limited partnerships. These securities are generally less liquid than the other types of securities we would invest in and are reserved for clients with a long-range goals. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet income requirements or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance 21 | P a g e February 2026  company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Private equity funds carry certain risks. Private equity fund investments do not sell publicly and are therefore illiquid. An investor may not be able to exit a private equity fund or sell its interests in the fund before the fund closes. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private equity funds are subject to various other risks, including the lack of control over the acquisition, management and disposition of investments and the investment risks associated with the types of assets and securities that the private equity fund invests in. 22 | P a g e February 2026  A brief description of the types of securities that Advisor will not likely invest in are listed below. Although Advisor does not typically invest discretionary dollars in these investment types, they are available to us to use. Clients should understand the risk they present. These investment types are listed alphabetically. Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; may involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Venture capital fund investments do not sell publicly and are therefore illiquid. An investor may not be able to exit a venture capital fund or sell its interest in the fund before the fund closes. Venture capital funds are subject to various other risks, including the lack of control over the acquisition, management and disposition of investments and the investment risks associated with the types of assets and securities that the venture capital fund invests in. 23 | P a g e February 2026  Item 9: Disciplinary Information A. Disciplinary Information There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-Regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. 24 | P a g e February 2026  Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither Advisor nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Advisor nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Advisor is an insurance licensed agency for Accident & Health, Life. Representatives of Advisor, who are properly licensed, will offer clients advice or products from these activities. Clients should be aware that insurance products pay a commission or other compensation. Commissionable products present a conflict of interest with our fiduciary duties; however, Advisor will always act in the best interest of its clients. Clients always have the option to purchase Advisor recommended products through other brokers or agents that are not affiliated with Advisor. Timothy Clepper is President of Kaulig Companies Ltd., a single member family office, and Kaulig Capital, LLC, the private investment arm of Kaulig Companies Ltd. Kaulig Capital, LLC, Kaulig Companies Ltd., and Advisor are under joint ownership; therefore, Timothy Clepper’s role with both the Kaulig companies and Advisor is a conflict of interest. Advisor mitigates this conflict of interest by always acting in the best interest of its clients. Alternative investments are not evaluated by the SEC and do pose a higher potential of loss to client’s investments in them. Cameron Miele is a Chief Executive Officer of several commercial fishing companies. Cameron provided alternative investment opportunities to some accredited clients, therefore his role as president of these companies results in a conflict of interest; however, Advisor mitigates this conflict by always acting in the best interest of its clients. Cameron receives a promote on these investments. D. Selection of Other Advisors or Managers and How This Advisor is Compensated for Those Selections Advisor has discretion to choose third-party investment advisors to manage all or a portion of the client's assets. Clients will pay Advisor its negotiated fee in addition to the fee for the advisors to which it directs those clients. This relationship will be memorialized in each contract between Advisor and each third-party advisor. The fees will not exceed any limit imposed by any regulatory agency. Advisor will always act in the best interests of the client, including when determining which third- party investment advisor to recommend to clients. Advisor will ensure that all recommended advisors are licensed, if applicable in the states in which Advisor is recommending them to clients. 25 | P a g e February 2026  Advisor always acts in the best interest of the client consistent with its fiduciary duties. Brokerage for Client Referrals Advisor receives no referrals from Charles Schwab & Co., Inc. (“Schwab”) or any third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use Clients cannot direct which broker/dealer/ custodian to use. Advisor will require clients to use Charles Schwab & Co., Inc. (“Schwab”) to execute transactions. Not all advisors require clients to use a particular broker-dealer. 26 | P a g e February 2026  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Pursuant to SEC rule 204A-1, Advisor has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Advisor's Code of Ethics is available at no charge upon request to any client or prospective client. Requests for a copy of Advisor’s Code of Ethics should be directed to the contact information on the cover page of this document. B. Recommendations Involving Material Financial Interests Advisor and its associated persons have material financial interest in investment opportunities that Advisor recommends for purchase or sale by clients. For example, alternative investments. This presents a conflict of interest in that Advisor, or its related persons may receive more compensation or a reduction in costs from the investment in a security in which Advisor or a related person has a material financial interest. To mitigate this conflict, client approval will be sought for client investment in such recommendations. These types of opportunities will only be made available to accredited or sophisticated investors who are already well diversified in traditional products. These types of opportunities may also be extended to related persons of Advisor, prospects, or other individuals who are well known by the senior management of Advisor. Advisor always acts in the best interest of the client consistent with its fiduciary duties and clients are not required to invest in such investments if they do not wish to do so. 27 | P a g e February 2026  C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of Advisor may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Advisor to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions create a conflict of interest. Advisor will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. To mitigate this conflict, Advisor always acts in the best interest of the client consistent with its fiduciary duties. In truth, the volume and dollar amount in which Advisor trades are unlikely to affect market prices. Even when transactions are executed in block/bulk trades. Nevertheless, block/bulk trading reports are reviewed against the trading activities of Advisor representatives at least quarterly. D. Trading Securities At/Around the Same Time as Client’s Securities From time to time, representatives of Advisor may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of Advisor to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions create a conflict of interest; however, Advisor will never engage in trading that operates to the client’s disadvantage if representatives of Advisor buy or sell securities at or around the same time as clients. To mitigate this conflict, Advisor always acts in the best interest of the client consistent with its fiduciary duties. In truth, the volume and dollar amount in which Advisor trades are unlikely to affect market prices. Even when transactions are executed in block/bulk trades. Nevertheless, block/bulk trading reports are reviewed against the trading activities of Advisor representatives at least quarterly. 28 | P a g e February 2026  Item 12: Brokerage Practices A. The Custodians and Brokers We Use Except in limited cases, Advisor does not maintain custody of your assets that we manage or on which we advise, although Advisor may be deemed to have custody of Client assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. Advisor requires that our clients use Charles Schwab & Co., Inc. (“Schwab”) as the qualified custodian. Advisor is independently owned and operated and is not affiliated with Schwab. Schwab will hold Client assets in a brokerage account and buy and sell securities when Advisor instructs them to. While Advisor requires that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). Client should consider these conflicts of interest when selecting your custodian. Advisor does not open the account for you, although we may assist you in doing so. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though the Client account is maintained at Schwab, and we anticipate that most trades will be executed through Schwab, Advisor can still use other brokers to execute trades for Client accounts as described below (see “Your brokerage and custody costs”). B. How We Select the Custodians and Brokers We Use Advisor seeks to use Schwab, custodian/brokers that will hold your assets and execute transactions. When considering whether the terms that Schwab provide are, overall, most advantageous to Clients when compared with other available providers and their services, Advisor considers a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) 29 | P a g e February 2026  C. Your Custody and Brokerage Costs Client’s accounts that Schwab maintains, Schwab generally does not charge Client separately for custody services but is compensated by charging Client commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For some accounts, Schwab charge you a percentage of the dollar amount of assets in the account in lieu of commissions. In addition to asset-based fees, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker- dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation Client pays the executing broker-dealer. Because of this, in order to minimize Client trading costs, Advisor will have Schwab execute most trades for your account. Advisor is not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although Advisor is not required to execute all trades through Schwab, Advisor has determined that having Schwab execute most trades is consistent with Advisor’s duty to seek “best execution” of Client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select the Custodians and Brokers We Use”). By using costs. another broker or dealer you may pay lower transaction D. Products and Services Available to Us Products and Services Available to Us from Charles Schwab & Co., Inc.(“Schwab”) Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like Advisor. They provide Advisor and our Clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through Advisor. Schwab also makes available various support services. Some of those services help Advisor manage or administer our Clients’ accounts, while others help Advisor manage and grow the business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: 30 | P a g e February 2026  Services that benefit Clients. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which Advisor might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Services that do not directly benefit Clients. Schwab also makes available to Advisor other products and services that benefit Advisor but do not directly benefit Client’s or their accounts. These products and services assist Advisor in managing and administering Clients’ accounts and operating the firm. They include investment research, both Schwab’s own and that of third parties. A d v is o r uses this research to service all or a substantial number of our Clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only Advisor. Schwab also offers other services intended to help Advisor manage and further develop the business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and related compliance needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Advisor. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides Advisor with other benefits, such as occasional business entertainment of our personnel. If Clients did not maintain your account with Schwab, Advisor would be required to pay for these services from our own resources. Participation in the Schwab Advisor Services™ program creates a conflict of interest for Advisor as Advisor will only open accounts with Schwab to keep these offerings which it would otherwise have to provide itself at a higher cost. This conflict of interest cannot be mitigated. 31 | P a g e February 2026  D. Our Interest in Schwab’s Services The availability of these services from Schwab benefits Advisor because we do not have to produce or purchase them. Advisor doesn’t have to pay for Schwab’s services. These services are not contingent upon Advisor committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that Advisor receives these benefits from Schwab is an incentive for us to require the use of Schwab rather than making such a decision based exclusively on Client’s interest in receiving the best value in custody services and the most favorable execution of Client transactions. This is a conflict of interest. Advisor believes, however, that taken in the aggregate, our selection of Schwab as custodian and broker is in the best interests of our Clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select the Custodians and Brokers We Use”) and not Schwab’s services that benefit only Advisor. E. Aggregating (Block) Trading for Multiple Client Accounts such case, Advisor would place an aggregate order If Advisor buys or sells the same securities on behalf of more than one Client, then it may (but would be under no obligation to) aggregate such securities in a single transaction for multiple Clients to seek more favorable prices (“Block” or “Bulk” trading), lower brokerage commissions, or more efficient execution. with In Schwab on behalf of all such Clients. Trades are reviewed periodically to ensure that some accounts are not systematically disadvantaged by this policy. Schwab would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution. 32 | P a g e February 2026  Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Clients of Advisor’s individual wealth management services are offered an annual review with the servicing advisor in conjunction with the portfolio manager, if requested. During this review the servicing manager will discuss the performance and allocation in the client’s accounts about their Investment Policy Statement. Advisor’s servicing advisors are: • Kelly Kuennen, President • Cameron Miele, Managing Director • Max Schindler, Managing Director • Patrick Justice, Managing Director • Brett Baskin, Director • John Dugan, Senior Vice President • Chris Ameen, Senior Vice President • David Jakubowski, Senior Vice President • Chris M. Prado, Senior Vice President • Kelly M. Orris, Associate Advisor and • Cade Tonozzi, Associate Advisor Advisor’s portfolio manager is Kelly Kuennen, President. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes to a client’s Investment Policy Statement. Investment Policy Statements can be and should be reviewed anytime the client has a change to their financial situation such as change in employment, adoption, or birth of a child, change in marital status, residential move, or inheritance, etc. C. Content and Frequency of Regular Reports Provided to Clients Each Client will be provided, at least quarterly, a report detailing the client’s account, including assets held, asset value, transactions within the account, and amount of fees charged. This written report will come from Schwab. Written performance reporting is also available quarterly or monthly at no additional charge. 33 | P a g e February 2026  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Economic Benefits Provided to Us from Charles Schwab & Co., Inc.(“Schwab”) Advisor receives an economic benefit from Schwab in the form of the support products and services it makes available to Advisor and other independent investment advisors whose clients maintain their accounts at Schwab. Client does not pay more for assets maintained at Schwab as a result of these arrangements. However, Advisor benefits from the referral arrangement because the cost of these services would otherwise be borne directly by Advisor. Client should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit Advisor, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). Economic Benefits Provided to Us from Vendors Advisor does not receive economic benefits in the form of sales awards or other prizes from Schwab, Orion Advisors, eMoney Advisors, insurance companies, or any vendors we contract with. As part of its fiduciary duties to clients, Advisor endeavors always to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a conflict of interest and may indirectly influence the Advisor's choice of Schwab for custody and brokerage services. This conflict of interest cannot be mitigated. B. Compensation to Non – Advisory Personnel for Client Referrals Advisor may enter into written arrangements with third parties to act as solicitors for Advisor's investment management services. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. Advisor will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with Rule 206(4)-3 under the Advisors Act, where applicable. Advisor does not currently have any written agreements with third parties to act as solicitors for Advisor’s investment management services. 34 | P a g e February 2026  Item 15: Custody A. Retail Accounts When advisory fees are deducted directly from client accounts at Schwab or if Client grant Advisor authority to move your money to another person’s account, Advisor will be deemed to have limited custody of client's funds and securities. Schwab maintains actual custody of Client assets. Clients will receive account statements directly from Schwab at least quarterly. They will be sent to the email or postal mailing address provided by Client. Clients should carefully review those statements promptly when received. Advisor also urges Clients to compare account statements with the periodic portfolio reports received. Once statements have been reviewed, they should be kept in a secure location or properly destroyed. B. Alternative Investments When clients invest in alternative investments offered by Advisor, the investment funds are sent directly to the private company. A bank account holds administrative fees to pay attorney, accounting, and other related expenses for the investment. The Managing Director and Chief Compliance Officer both have access to these funds to facilitate the payment of expenses. 35 | P a g e February 2026  Item 16: Investment Discretion Advisor provides discretionary and non-discretionary investment advisory services to clients. The Investment Management Agreement established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, Advisor generally manages the client’s account and makes investment decisions without consultation with the client as to: i. when the securities are to be bought or sold for the account, ii. the total amount of the securities to be bought/sold, iii. what securities to buy or sell, or the price per share. In limited instances, Advisor’s discretionary authority in making these determinations may be limited by conditions imposed by a client in investment guidelines or objectives, or client instructions otherwise provided to Advisor. Client must make note of these conditions in writing on the Investment Management Agreement. 36 | P a g e February 2026  Item 17: Voting Client Securities (Proxy Voting) Advisor acknowledges its fiduciary obligation to vote proxies on behalf of those clients that have delegated to it, or for which it is deemed to have, proxy voting authority. Advisor will accept voting authority for client securities in certain cases. When Advisor does accept voting authority for client securities, it will always seek to vote in the best interests of its clients. Clients may direct Advisor on how to vote client securities by communicating their wishes in writing or electronically to Advisor. When voting client proxies, Advisor will always hold the interests of the clients above its own interests. Clients of Advisor may obtain the voting records or written policies and procedures for proxy voting by contacting Advisor at the phone number or e-mail address listed on the cover page of this brochure. Item 18: Financial Information A. Balance Sheet Advisor neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Advisor nor its management has any financial condition that is likely to reasonably impair Advisor’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years Advisor has not been the subject of a bankruptcy petition in the last ten years. 37 | P a g e February 2026 

Item 1: Cover Page This Wrap Fee Program Brochure (Form ADV Part 2A - Appendix 1) provides important information about Ellsworth Advisor’s wrap fee program, including information about the services provided and the fees you will pay. Please contact Michelle Schwab, Chief Compliance Officer if you have any questions about the contents of this brochure. Additional information about Ellsworth Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Ellsworth Advisors, LLC’s CRD number is: 297464. 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. Registration does not imply a certain level of skill or training. Investing in individual stocks, mutual funds, fixed income securities, insurance products (including annuities), hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), non-U.S. securities, venture capital funds and private placement has the potential for loss of all invested dollars. 1764 Georgetown Road Hudson, Ohio 44236 Phone: 234.901.2831 Fax: 234.252.2461 mschwab@ellsworthadvisors.com www.ellsworthadvisors.com 1 | P a g e Version: August 2025  Item 2: Material Changes There are no material changes in this brochure from the last annual updating amendment to this Wrap Fee Program Brochure on January 2023. Material changes relate to Ellsworth Advisors, LLC’s policies, practices, or conflicts of interests only. 2 | P a g e Version: August 2025  Item 3: Table of Contents Item 1: Cover Page ....................................................................................................................................... 1 Item 2: Material Changes............................................................................................................................. 2 Item 4: Services Fees and Compensation ................................................................................................... 5 A. Description of Services: ............................................................................................................................... 5 B. Conflict of Interest ...................................................................................................................................... 6 C. Contribution Cost Factors ............................................................................................................................ 7 D. Compensation to Advisor .......................................................................................................................... 7 Item 5: Account Requirements and Types of Clients .................................................................................. 8 Item 6: Portfolio Manager Selection and Evaluation .................................................................................. 9 A. Selecting/Reviewing Portfolio Managers .................................................................................................... 9 Standards Used to Calculate Portfolio Manager Performance ................................................................... 9 Review of Performance Information ........................................................................................................... 9 B. Related Persons .......................................................................................................................................... 9 C. Advisory Business ........................................................................................................................................ 9 Item 7: Client Information Provided to Portfolio Managers ....................................................................... 9 Item 8: Client Contact with Portfolio Managers ....................................................................................... 10 Item 9: Additional Information ................................................................................................................. 10 A. Disciplinary Action and Other Financial Industry Activities ..................................................................... 10 Criminal or Civil Actions ............................................................................................................................. 10 Administrative Proceedings ....................................................................................................................... 10 Self-regulatory Organization Proceedings ................................................................................................. 10 Registration as a Broker/Dealer or Broker/Dealer Representative ........................................................... 10 Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor ....................................................................................................................................................... 10 Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests .......... 11 Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections ................................................................................................................................................................... 12 Code of Ethics, Client Referrals, and Financial Information ...................................................................... 12 Recommendations Involving Material Financial Interests ........................................................................ 12 Investing Personal Money in the Same Securities as Clients..................................................................... 13 Trading Securities At/Around the Same Time as Clients’ Securities ......................................................... 13 Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ........................................... 14 3 | P a g e Version: August 2025  Factors That Will Trigger a Non-Periodic Review of Client Accounts ........................................................ 14 Content and Frequency of Regular Reports Provided to Clients ............................................................... 15 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) .......................................................................................................................................... 15 Compensation to Non – Advisory Personnel for Client Referrals .............................................................. 15 Balance Sheet ............................................................................................................................................ 15 Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ................................................................................................................................................................... 15 Bankruptcy Petitions in Previous Ten Years .............................................................................................. 15 4 | P a g e Version: August 2025  Item 4: Services Fees and Compensation Ellsworth Advisors, LLC (“Advisor”) offers the following services to advisory clients (“Client”): A. Description of Services: Advisor participates in and sponsors a wrap fee program, Ellsworth Advisors, LLC Wrap Fee Program (“Advisory Wrap Fee Program”). Our wrap fee program allows you to pay a single fee that covers advisory services, trade execution, custody, and other standard brokerage services. Advisory Services: Advisor will direct the securities to be bought or sold, the share or dollar amount of securities to be bought or sold, and when the securities will be bought or sold. Schwab’s Brokerage Services In addition to the advisory services, the wrap fee program includes certain brokerage services of Charles Schwab & Co., Inc. (“Schwab”) a broker- dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC. We are independently owned and operated and not affiliated with Schwab. Schwab will act solely as a broker-dealer and not as an investment advisor to you. It will have no discretion over your account and will act solely on instructions it receives from us [or you]. Schwab has no responsibility for our services and undertakes no duty to you to monitor our firm’s management of your account or other services we provide to you. Schwab will hold your assets in a brokerage account and buy and sell securities and execute other transactions when we [or you] instruct them to. We do not open the account for you. Fees for Wrap Program Advisor charges a single asset-based fee for services covered by the wrap program. All assets in a Client Managed Account will be charged the same fee. The fee is negotiable, and the maximum is 1.00% on an annual basis. The final fee is documented in the Schedule A of the Agreement. Client will be charged the Advisory Fee memorialized in the Investment Management Agreement (“Agreement”) and Advisor will cover most transaction fees. The fees not included in Advisory Fees are detailed in Item 4.C. Contribution of Cost Factors. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity. 5 | P a g e Version: August 2025  To calculate the monthly fees, Advisor uses the average daily balance in the client's account throughout the billing period for purposes of determining the market value of the assets. This market value is used to calculate the monthly fees by multiplying the average daily balance by the negotiated fee. This value is then multiplied by the number of days in the month divided by the number of days in the year. Advisor charges a single asset-based fee for services covered by the wrap program. The maximum fee charged for the program is 1.00%. ((Average daily balance market value) x (negotiated annual fee)) X ((days in the billing month) / (days in the year)) Example: $100,000 * .01 = $1,000 30 days / 365 = .082 $1,000 * .082 = $82.19 for the monthly fee With the client’s written permission, Advisor deducts fees directly from the client’s account(s). Fees are deducted monthly and in arrears. All of the fees collected are kept by Advisor as the portfolio manager. Fees We Pay Schwab In addition to compensating Advisor for advisory services, the wrap fee you pay Advisor allows us to pay for brokerage and execution services provided by Schwab. Advisor will pay the following fees to Schwab on the Client’s behalf:  Commissions: Schwab generally does not charge commissions or transaction fees for online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no- transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these types of securities, we can do so without paying commissions to Schwab.  Asset-base service fees o Fees for Schwab’s Prime Brokerage, Step-In, and Trade-Away Services o Exchange Process Fees o Mutual fund short-term redemption fees B. Conflict of Interest A wrap fee is not based directly on the number of transactions in your account. Various factors influence the relative cost of our wrap fee program to you, including the cost of our investment advice, custody, and brokerage services if you purchased them separately, the types of investments held in your account, and the frequency, type and size of trades in your account. The program could cost you more or less than purchasing our investment advice and custody/brokerage services separately. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income 6 | P a g e Version: August 2025  securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. C. Contribution Cost Factors The program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program: • • • including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately. Client understands that additional fees or charges may result from maintenance of, or trading within, the Managed Account. Client understands and agrees that any additional fees, charges, or expenses resulting from maintenance of, or trading within, the Managed Account not covered by the wrap fee shall be the sole responsibility of the Client. Our wrap fee does not include the fees and costs listed below. The fees and costs may apply to transactions in your account. The fees and costs not included in the wrap fee that you will pay include: a Commissions and other fees charged by broker-dealers other than Schwab for transactions in your account if Advisor uses Schwab’s Prime Brokerage, Step-In, or Trade Away Services. Because you will pay our wrap fee in addition to any charges paid to broker-dealers other than Schwab, we have an incentive to execute transactions for your account through Schwab. b Fees charged by mutual fund companies, closed-end funds, electronically traded funds, and other collective investment vehicles, including, but not limited to, sales loads and/or charges and short-term redemption fees. c Markups and markdowns, bid-ask spreads, and selling concessions in connection with transactions Schwab executes as principal. Principal transactions contrast with transactions in which Schwab acts as your agent in effecting trades. Markups and markdowns and bid-ask spreads are not separate fees but are reflected in the net price at which a trade order is executed. d Costs imposed by third parties, such as transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, and any other fees required by law. Schwab may also charge for additional services such wire transfer fees and fees for alternative investments. e Taxes on brokerage accounts and securities transactions. These fees and expenses are collected by Custodian and are not paid to Advisor. D. 7 | P a g e Version: August 2025  Compensation to Advisor When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap fee you pay after custodial, trading, and other management costs including execution and transaction fees have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. For example, our wrap fee arrangement creates incentives for Advisor to trade less frequently or select investments that that reduce our costs, and in some cases increase expenses that are borne by the client. Item 5: Account Requirements and Types of Clients Although Advisor can choose who may become a client, there are no requirements or account minimums for any of Advisors services. Advisor generally provides the Advisory Wrap Fee Program to the following types of clients: Individuals • • High-Net-Worth Individuals • Corporations or Other Businesses • Pension and Profit-Sharing Plans 8 | P a g e Version: August 2025  Item 6: Portfolio Manager Selection and Evaluation A. Selecting/Reviewing Portfolio Managers Advisor will not select any outside portfolio managers for management of the Advisory Wrap Fee Program. Advisor will be the sole portfolio manager for the Advisory Wrap Fee Program. Standards Used to Calculate Portfolio Manager Performance Industry standards are used to calculate portfolio manager performance. Review of Performance Information A third party, Orion Advisors, reviews the performance information to determine and verify its accuracy and compliance with presentation standards. The performance information is received monthly from Orion Advisors and is reviewed by Advisor. B. Related Persons Advisor and its personnel serve as the portfolio managers for all Advisory Wrap Fee Program accounts (“Managed Accounts”). This is a conflict of interest because no outside adviser assesses Advisors management of the Advisory Wrap Fee Program. However, Advisor mitigates this conflict by acting in its clients’ best interest consistent with its fiduciary duty as sponsor and portfolio manager of the wrap fee program. C. Advisory Business Advisor offers portfolio management services to Advisory Wrap Fee Program participants as discussed in Item 4 above. Please refer to our Ellsworth Advisors, LLC Firm Brochure (Form ADV Part 2A) for details on the other services provided by Advisor. Item 7: Client Information Provided to Portfolio Managers All client information material to managing the portfolio is provided to the portfolio manager in the form of the Investment Policy Statement. The portfolio manager has access to that information as it changes and is updated. 9 | P a g e Version: August 2025  Item 8: Client Contact with Portfolio Managers Advisor places no restrictions on Client ability to contact its portfolio managers. Advisor’s President, Kelly Kuennen, can be contacted during regular business hours. Kelly M. Kuennen, CFP® 1764 Georgetown Road Hudson, OH 44236 kkuennen@ellsworthadvisors.com (234) 200-0703 Item 9: Additional Information A. Disciplinary Action and Other Financial Industry Activities Criminal or Civil Actions There are no criminal or civil actions to report. Administrative Proceedings There are no administrative proceedings to report. Self-regulatory Organization Proceedings There are no self-regulatory organization proceedings to report. Registration as a Broker/Dealer or Broker/Dealer Representative Neither Advisor nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither Advisor nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor. 10 | P a g e Version: August 2025  Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Advisor is an insurance licensed agency for Accident & Health, Life. Representatives of Advisor, who are properly licensed, will offer clients advice or products from these activities. Clients should be aware that insurance products pay a commission or other compensation that is not included in the Advisory Fee. Commissionable products create a conflict of interest because the Advisor would receive additional compensation above Advisory Fees. To mitigate this conflict, Advisor will always act in the best interest of its clients. Additionally, clients always have the option to purchase Advisor recommended products through other brokers or agents that are not affiliated with Advisor. Timothy Clepper is President of Kaulig Companies Ltd., a single member family office, and Kaulig Capital, LLC, the private investment arm of Kaulig Companies Ltd.. Kaulig Capital, LLC, Kaulig Companies Ltd., and Advisor are under joint ownership; therefore, Timothy Banks Clepper’s role with both the Kaulig companies and Advisor could result in a conflict of interest. To mitigate this conflict, Advisor will always act in the best interest of its clients. Kaulig Capital, LLC researches private equity and real estate opportunities (“Alternative Investments”) for the benefit of Matthew Kaulig, the indirect owner of Advisor. Kaulig Capital may receive financial benefits for raising additional capital for Alternative Investment. This creates a conflict of interest. To mitigate this conflict, Advisor will always act in the best interest of its clients. Additionally, Advisor’s discretion does not include Alternative Investments and clients need to agree on a case-by-case basis whether or not to invest. Clients always have the option to purchase Advisor recommended products through other brokers or agents that are not affiliated with Advisor. Cameron Miele is the Chief Executive Officer of several commercial fishing companies. Mr. Miele provided a private equity opportunity to some clients. This creates a conflict of interest. Advisor mitigates this conflict by always acting in the best interest of its clients. Additionally, clients always have the option to purchase Advisor recommended products through other brokers or agents that are not affiliated with Advisor. 11 | P a g e Version: August 2025  Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections In some cases, a third-party manager or Sub-Advisor is requested by the client or deemed in the client’s best interest by Advisor. In these cases, the Advisor will enter into a Sub-Advisor arrangement with the third-party. The details of this Sub-advisor relationship will be detailed in their Form ADV Part 2A (Firm Brochure) or Form ADV Part 2A Appendix 1 (Wrap Fee Program Brochure) provided by the Sub-Advisor. Sub-Advisor will direct the securities to be bought or sold, the share or dollar amount of securities to be bought or sold, and when the securities will be bought or sold. Client will be charged the Advisory Fee and the Sub-Advisor Advisory Fee. The Advisor or Sub-Advisor will cover most of the transaction charges. The fees not included in Advisory Fees for wrap services are detailed in Section 3: Additional Fees and Charges of the Agreement. If a sub-advisor is discontinued, the account will revert to an Advisory Wrap Fee Program. Code of Ethics, Client Referrals, and Financial Information Pursuant to SEC rule 204A-1, Advisor has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Advisor's Code of Ethics is available at no charge upon request to any client or prospective client. Requests for a copy of Advisors Code of Ethics should be directed to the contact information in Item 1: Cover Page of this document. Recommendations Involving Material Financial Interests Advisor and its associated persons may have material financial interests in issuers of securities that Advisor may recommend for purchase or sale by clients. For example, Alternative Investments. This presents a conflict of interest. Advisor, or its related persons, may receive more compensation or a reduction in costs for recommending the Alternative Investment to clients. To mitigate this conflict, Advisor will always act in the best interest of its clients. Additionally, Advisor’s discretion does not include Alternative Investments and clients need to agree on a case-by-case basis whether to invest. Clients always have the option to purchase Advisor recommended products through other brokers or agents that are not affiliated with Advisor. 12 | P a g e Version: August 2025  Investing Personal Money in the Same Securities as Clients From time to time, representatives of Advisor may buy or sell securities for themselves that they also recommend to clients. This creates a conflict of interest in that this may provide an opportunity for representatives of Advisor to buy or sell the same securities before or after recommending the same securities to clients. This type of activity could result in representatives profiting off the recommendations they provide to clients. To mitigate this conflict, Advisor will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Advisor always acts in the best interest of the client consistent with its fiduciary duties. The volume and dollar amount in which Advisor trades are unlikely to affect market prices. Even when transactions are executed in block/bulk trades. Nevertheless, block/bulk trading reports are reviewed against the trading activities of Advisors representatives regularly. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of Advisor may buy or sell securities for themselves at or around the same time as clients. This creates a conflict of interest in that this may provide an opportunity for representatives of Advisor to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. To mitigate this conflict, Advisor will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Advisor always acts in the best interest of the client consistent with its fiduciary duties. The volume and dollar amount in which Advisor trades are unlikely to affect market prices. Even when transactions are executed in block/bulk trades. Nevertheless, block/bulk trading reports are reviewed against the trading activities of Advisors representatives regularly. 13 | P a g e Version: August 2025  Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Clients are offered an annual review with the servicing advisor in conjunction with the portfolio manager, if requested. During this review, the servicing manager will discuss the performance and allocation in the client’s accounts as it relates to their Investment Policy Statement. Ellsworth Advisors servicing advisors are: Kelly Kuennen, President Cameron Miele, Managing Director Max Schindler, Managing Director Patrick Justice, Managing Director Brett Baskin, Director Dave Jakubowski, Senior Vice President Chris Ameen, Senior Vice President John Dugan, Senior Vice President Chris Prado, Senior Vice President Kelly Orris, Associate Advisor Cade Tonozzi, Associate Advisor Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes to a client’s Investment Policy Statement. Investment Policy Statements can be and should be adjusted anytime the client has a change to their financial situation such as change in employment, adoption, or birth of a child, change in marital status, residential move, or inheritance, etc. 14 | P a g e Version: August 2025  Content and Frequency of Regular Reports Provided to Clients Each Client will be provided, at least quarterly, a report detailing the client’s account, including assets held, asset value, transactions within the account, and amount of fees charged. This written report will come from Charles Schwab & Co., Inc.. Written performance reporting is also available quarterly or monthly at no additional charge. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Advisor does not receive economic benefits in the form of sales awards or other prizes from Charles Schwab & Co., Inc., Orion Advisors, eMoney Advisors or insurance companies. As part of its fiduciary duties to clients, Advisor endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a conflict of interest and may indirectly influence Advisor’s choice of Charles Schwab & Co., Inc. for custody and brokerage services. This conflict of interest cannot be mitigated. Compensation to Non – Advisory Personnel for Client Referrals Advisor may enter into written arrangements with third parties to act as solicitors for Advisor’s investment management services. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. Advisor will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with Rule 206(4)-3 under the Advisers Act, where applicable. Advisor does not currently have any written agreements with third parties to act as solicitors for Advisor’s investment management services. Balance Sheet Advisor neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Advisor nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years Advisor has not been the subject of a bankruptcy petition in the last ten years. 15 | P a g e Version: August 2025