GENEREUX INVESTMENT MANAGEMENT, INC.

Item 1 – Cover Page Genereux Investment Management, Inc. 1176 Anglers Drive Steamboat Springs, Colorado 80487 (712) 256-7500 http://www.genereux.net Date of Brochure: October 2025 This brochure provides information about the qualifications and business practices of Genereux Investment Management, Inc. If you have any questions about the contents of this brochure, please contact Mark Genereux at (712) 256-7500 or at mark@genereux.net. 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 Genereux Investment Management, Inc. is also available on the Internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for Genereux Investment Management, Inc. You may search for information by using the firm’s IARD number. The IARD number for Genereux Investment Management, Inc. is 117436. *Registration as an investment advisor does not imply a certain level of skill or training.  Item 2 – Material Changes Since our last annual update was filed in February 2025, the following material changes have been made to our disclosure brochure. • Items 4 & 5 – Added discretionary sub-advisory services of SpiderRock Advisors, LLC, an SEC registered investment adviser firm, and the related fees associated with clients whose portfolios or accounts are allocated to the subadviser. • Item 8 – Certain risks, including those pertaining to options trading, puts and calls, derivatives, and eligible collateral instruments, have been added. We will ensure that you receive a summary of material changes, if any, to this and subsequent disclosure brochures within 120 days after our fiscal year ends. Our fiscal year ends on December 31 so you will receive the summary of material changes, if any, no later than April 30 each year. At that time we will also offer a copy of the most current disclosure brochure. We may also provide other ongoing disclosure information about material changes as necessary. 2 Genereux Investment Management, Inc. Disclosure Brochure  Item 3 – Table of Contents Item 1 – Cover Page ..................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 4 General Description of Primary Advisory Services ................................................................................... 4 Investment Management Services ........................................................................................................ 4 Specialization ............................................................................................................................................ 6 Limits Advice to Certain Types of Investments. ........................................................................................ 7 Tailor Advisory Services to Individual Needs of Clients ............................................................................ 7 Client Assets Managed by Advisor ........................................................................................................... 7 Item 5 – Fees and Compensation ................................................................................................................. 7 Investment Management Services ............................................................................................................ 7 Additional Compensation .......................................................................................................................... 9 Comparable Services ................................................................................................................................ 9 Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................... 10 Item 7 – Types of Clients ............................................................................................................................ 10 Minimum Investment Amounts Required ................................................................................................ 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 10 Methods of Analysis ................................................................................................................................ 10 Investment Strategies ............................................................................................................................. 11 Risk of Loss ............................................................................................................................................. 12 Primary Method of Analysis or Strategy .................................................................................................. 14 Primarily Recommend One Type of Security .......................................................................................... 14 Item 9 – Disciplinary Information ................................................................................................................. 14 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 14 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 15 Code of Ethics Summary ........................................................................................................................ 15 Participation in Client Transactions and Personal Trading ..................................................................... 15 Item 12 – Brokerage Practices .................................................................................................................... 15 Trade Errors ............................................................................................................................................ 17 Block Trades ........................................................................................................................................... 17 Item 13 – Review of Accounts .................................................................................................................... 18 Account Reviews ..................................................................................................................................... 18 Account Statements & Reports ............................................................................................................... 18 Item 14 – Client Referrals and Other Compensation .................................................................................. 18 Client Referrals ....................................................................................................................................... 18 Other Compensation and Non-Client Economic Benefit ......................................................................... 18 Item 15 – Custody ....................................................................................................................................... 18 Item 16 – Investment Discretion ................................................................................................................. 19 Item 17 – Voting Client Securities ............................................................................................................... 19 Item 18 – Financial Information ................................................................................................................... 19 Customer Privacy Policy Notice…...……………………………………………………………………………...19 3 Genereux Investment Management, Inc. Disclosure Brochure  Item 4 – Advisory Business Genereux Investment Management, Inc. (“Advisor” or “we”) is an investment advisor registered with The Securities and Exchange Commission (“SEC” since November 2017) and notice filed with state securities regulators in Iowa (Since February 2012) and Colorado (Since February 2016) and other applicable states based upon where a client resides and the requirements of such state. We are a corporation formed under the laws of the State of Colorado and Mark A. Genereux is our sole owner. General Description of Primary Advisory Services We offer personalized advisory services including financial planning, consultations and investment management. The following are brief descriptions of our primary services. A detailed description is provided in Item 5, Fees and Compensation, so that clients and prospective clients (“clients” or “you”) can review the services and description of fees more thoroughly. Investment Management Services We offer investment management services by providing clients with ongoing and continuous portfolio management services that include, but are not limited to, risk management, investment policy, asset allocation, active or passive implementation, and performance monitoring. These services are typically implemented using exchange traded funds, mutual funds, separately managed accounts and individual securities. Depending on your needs, we may evaluate or recommend U.S. Government securities, tax- exempt municipal bonds and other fixed-income securities. This means that we continuously monitor a client’s account and make trades in that account when necessary. With your input, we attempt to construct a diversified portfolio of investments within our realm of expertise. Additionally, based on information provided by you, we prepare an evaluation of existing portfolio investments and provide recommendations for other investments as appropriate. We assist you in establishing a managed account(s) through a qualified custodian. We recommend the use of Charles Schwab Brokerage, Inc. Institutional Brokerage Group (“Charles Schwab”), although you are free to select any qualified custodian you wish by providing us with written direction. We require a minimum of $1,000,000 to establish an account. Charles Schwab or your selected custodian maintains custody of all your funds and securities. We do not act as custodian and do not have direct access to client funds and securities except for the ability to have advisory fees deducted by the custodian and paid to us with your prior written authorization. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We are granted trading authorization on your accounts and provide these management services on a discretionary basis only. This means we make all decisions to buy, sell or hold securities, cash or other investments in the managed account in our sole discretion without consulting with you before making any transactions. You must provide us with written authorization to exercise this discretionary authority, and you can place reasonable restrictions and limitations on the discretionary authority. See Item 16, Investment Discretion, for additional discussion on discretionary and non-discretionary authority. When Genereux Investment Management provides you with investment management services, our financial planning services are included. We can help individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning and other areas. Our role is to find ways to help clients understand their overall financial situation and help them set financial objectives. Our financial planning services focus on either a client’s overall financial situation or on specific areas of client concern. 4 Genereux Investment Management, Inc. Disclosure Brochure  When appropriate and based on your identified needs, we can provide value-added financial planning services as part of our investment management services. Our financial planning services consist of discovery, analysis and recommendations pertaining to one or more of the following considerations, or based upon needs identified by you: Income distribution planning for retirement IRA or employer-sponsored retirement plan rollovers IRA required minimum distributions • Retirement Planning • Analysis and recommendations relating to cash management issues • • Employee stock option evaluation • • • College funding for children or grandchildren • Life Insurance and/or Disability Income Insurance • Annuities • Mortgages • Estate Preservation & Wealth Transfer Planning • Charitable & Philanthropic Planning We can provide you with oral or written reports on any of these areas selected by you. Retirement Plan Rollover Recommendations When we provide investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that Advisor is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way we make money creates conflicts with your interests so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, we must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC: • • • • • • Meet a professional standard of care when making investment recommendations (e.g., give prudent advice); Never put the financial interests of Advisor ahead of you when making recommendations (e.g., give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that Advisor gives advice that is in your best interest; Charge no more than is reasonable for the services of Advisor; and Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by us, please know that Advisor and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by us. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Advisor. 5 Genereux Investment Management, Inc. Disclosure Brochure  Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Advisor receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Advisor and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Advisor or our affiliated personnel. SpiderRock Advisors, LLC SubAdvisory Investment Management Services For certain high net worth clients with concentrated stock positions we offer discretionary asset management services through SpiderRock Advisors, LLC, an SEC registered investment adviser and CFTC Commodity Trading Advisor. SpiderRock Advisors, LLC, uses proprietary overlay investment strategies designed to mitigate risk and achieve greater portfolio returns. The strategies involve utilizing derivatives, including equity and index options, collateral asset management, and trading over-the-counter securities. SpiderRock Advisors, LLC will have the sole and exclusive responsibility for making all of the management decisions for each of the select client accounts chosen for this service. Genereux Investment Management, Inc. will continue to review and supervise these accounts. These services are designed to complement our existing advisory offerings by incorporating tailored strategies that seek to enhance portfolio diversification, manage risk, and generate income. Clients eligible for this service typically meet certain financial thresholds and investment sophistication criteria and are subject to certain suitability assessments. Investments will be subject to restrictions and/or limitations communicated to Genereux Investment Management, Inc. by clients. Clients will receive additional disclosures regarding the nature, risks, and costs associated with these strategies prior to implementation. Please refer to SpiderRock Advisors, LLC’s Form ADV Part 2A Firm Brochure for additional information. Specialization We specialize in asset allocation and risk management. 6 Genereux Investment Management, Inc. Disclosure Brochure  Limits Advice to Certain Types of Investments. We provide investment advice on the following types of investments: • Exchange-listed securities • Securities traded over-the-counter • Foreign issues • Warrants • Corporate debt securities (other than commercial paper) • Commercial paper • Certificates of deposit • Municipal securities • Variable annuities • Mutual fund shares • United States government securities • Option contracts on securities Although our advice is generally limited to the investment products previously listed, we reserve the right to offer advice on any product that may be suitable for each client’s specific circumstances, needs, goals and objectives. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, for more information. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the specific needs of the individual client. Clients are given the ability to impose restrictions on their accounts, including specific investment selections and sectors. However, we will not enter into an investment advisor relationship with anyone whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by Advisor The amount of client’s assets managed by Advisor totaled $127,748,913 as of October 14, 2025, with all accounts managed on a discretionary basis. Item 5 – Fees and Compensation In addition to the information provided in Item 4, Advisory Business, this section provides details regarding each service’s fees and compensation arrangements. We may offer an initial complimentary general consultation to discuss services available, needed and desired and to determine the suitability of a potential client-advisor relationship. Investment advisory services only begin after we formalize our relationship with you by signing an advisory agreement. Once the relationship is initiated, we begin a data gathering and discovery process in a joint effort to try to determine your personal needs, goals, intentions, time horizons, risk tolerance and investment objectives. Investment Management Services With respect to our investment management services, we charge for investment management services based on a percentage of assets under management. Fees are billed quarterly in arrears and are calculated on the market value of the account as shown by the custodian on the last trading day of the billable quarter. 7 Genereux Investment Management, Inc. Disclosure Brochure  An annual fee of 1% is charged on assets under management. In certain situations, we may negotiate our fee according to individual circumstances (i.e., the size of the account, the complexity of services required, pre-existing relationships, or referrals from existing clients or for family members of our associated persons). If asset management services are commenced in the middle of the initial billing period (other than the first business day of the initial billing period), (a) the fee for the initial billing period is prorated based upon value of the Account when the service commenced and the number of days that service was provided during the initial billing period, and (b) the prorated fee for the initial billing period will be deducted in arrears at the same time as the next full billing period’s fee is billed. With respect to the final billing period, the fees for a billing period will be prorated based on the number of days that services were provided during the billing period. Fees may be billed directly to you or by a debit directly to your account by the qualified custodian. Advisor will send you a fee billing invoice showing the amount of the fee to be deducted, the manner in which the fee was calculated, any adjustments to the fee and an explanation of such adjustments. The Securities and Exchange Commission and many state securities regulators have taken the position that account access to facilitate fee deduction results in custody of funds unless certain safeguards are in place. To avoid any issue of custody, we adhere to the following criteria when payment is made by the custodian when debiting your account: (1) You provide written authorization permitting the fees to be paid directly from your account held by the independent and qualified custodian and that authorization is limited to withdrawing contractually agreed upon investment advisor fees. (2) You receive regular account statements (at least quarterly) from the qualified custodian that reflects our advisory fee deduction. (3) The frequency of fee withdrawal is specified in the written authorization/agreement. (4) The account custodian is advised in writing of our limited access to your account. (5) You can terminate the written billing authorization or agreement at any time. You should review the fee billing invoice received from us and the account statements received from your account custodian and verify that appropriate advisory fees are being deducted. If you have questions about the fee billing invoice or the account statements, you should contact us or your custodian. Charles Schwab does not generally charge separately for maintaining custody of your accounts, but other qualified custodians selected by you may charge a separate custody fee. Account custodians may charge brokerage commissions and/or transaction fees directly to you. We do not receive any portion of the commission or fees from either the custodian or from you. In addition, you will incur certain charges imposed by third parties other than us in connection with investments made through your account, including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges and IRA and qualified retirement plan fees. Our management fees are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each security prospectus. As stated in Item 4, financial planning services are provided as part of our investment management services when Genereux Investment Management is providing investment management services for you for a fee. Investment management services continue until terminated, and either party can terminate services at any time by providing written notice to the other. Termination is effective upon receipt of the notice. If 8 Genereux Investment Management, Inc. Disclosure Brochure  services are terminated within five business days of signing the client agreement, services are terminated without fee or penalty and no fees are due. Assets Under Investment Management Fee An annual fee of 1% is charged on assets under consultation. Fees are billed quarterly in arrears and calculated based on the fair market value of the assets on the last business day of the current billing period, multiplied by the advisory fee, then divided by 4. SubAdvisory Services of SpiderRock Advisors, LLC Fees for subadviser services provided by SpiderRock Advisors, LLC to Genereux Investment Management clients will be directed debited from your account in advance on a quarterly basis by the qualified custodian. The annual fees, depending upon the proprietary model chosen, range from .50% - .85% of assets under management calculated on a daily basis and determined by ticker, calculated as the dollar value of the underlying assets being hedged in each client’s allocated investment program accounts. If applicable, the client’s account being managed by SpiderRock Advisors, LLC will be determined using a Household Fee Tier schedule as contained within the SpiderRock Advisors, LLC Form ADV Part 2A Firm Brochure. The Household Fee Tier only applies to certain investment strategy models. Fees for collateral management accounts will be payable in arrears on each repurchase date in an amount equal to .15% per annum of the aggregate par amount of all collateral assets held in the client’s account with SpiderRock Advisors, LLC. The Collateral Management Fee will be calculated on the basis of a calendar year consisting of 360 days and the actual number of days elapsed. Other Financial Planning and Investment Consulting Fee Terms If you choose to pay fees directly by check, the advisory fees for services will be due immediately after client’s receipt of the billing invoice. When providing services under this Agreement to you, you may coordinate and/or consult with attorneys, accountants or other outside professionals which have been retained by you; however, you will be responsible for the payment of the fees for the services of such outside professionals, and Genereux Investment Management will not be required to reimburse. The services under this Agreement are continuous until terminated. The services will terminate upon either party providing written notice of termination to the other party. If you terminate the services under this Agreement within 5 days of the execution of this Agreement, there will be no penalty and you will receive a full refund of any pre-paid advisory fees. Additional Compensation We do not receive any compensation other than the advisory fees discussed previously in this Disclosure Brochure. Comparable Services We believe our fees for advisory services are reasonable with respect to the services provided and the fees charged by other investment advisors offering similar services. However, lower fees for comparable services may be available from other sources. 9 Genereux Investment Management, Inc. Disclosure Brochure  Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s account. We do not receive performance-based fees. Item 7 – Types of Clients We generally provide investment advice to the following types of clients: Individuals (including high net worth individuals) • • Trusts, estates, or • charitable organizations We provide advice and services to foundations and high net worth individuals. Minimum Investment Amounts Required We require a $1,000,000 minimum to establish and maintain a managed account; however, we reserve the right to make exceptions to this minimum. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We use fundamental, technical, cyclical and charting methods of analysis when considering investment strategies and recommendations for clients. Fundamental Fundamental analysis is a method of evaluating a company or security by attempting to measure its intrinsic value. In other words, fundamental analysts try to determine its true value by looking at all aspects of the business, including both tangible factors (e.g., machinery, buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves examining related economic factors (e.g., overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity and price-to-equity ratios). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method of security analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. Technical This method of evaluating securities analyzes statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. 10 Genereux Investment Management, Inc. Disclosure Brochure  Cyclical Cyclical analysis looks at recurring periods of expansion and contraction that can impact a company’s profitability and cash flow. Cyclical stocks tend to rise quickly when the economy turns up and fall quickly when the economy turns down (i.e., housing, automobiles, telecommunications, paper, etc.). Non-cyclical industries (i.e., food, insurance, drugs, health care, etc.) are not as directly impacted by economic changes. Charting Charting is a technical analysis that charts the patterns of stocks, bonds and commodities to help determine buy and sell recommendations for clients. It is a way of gathering and processing price and volume information in a security by applying mathematical equations and plotting the resulting data onto graphs in order to predict future price movements. A graphical historical record assists the analyst in spotting the effect of key events on a security’s price, its performance over a period of time and whether it is trading near its high, near its low or in between. Chartists believe that recurring patterns of trading, commonly referred to as indicators, can help them forecast future price movements. SpiderRock Advisors, LLC uses quantitative and technical valuation models to implement its investment strategies. Investment Strategies The investment strategies we use when implementing investment advice include: Long term purchases (securities held at least a year.) We provide advisory services for portfolios ranging from aggressive to conservative, all designed to meet the varying needs of investors. We assist and consult with you about selecting the portfolio best suited to your individual need after you have defined your objectives, risk tolerance and time horizons. You may elect to have us implement a portfolio strategy that includes a combination of passive and actively managed investment styles. Portfolios are diversified in various asset classes, reviewed quarterly and re- balanced quarterly or annually pursuant to either your direction or our discretion. You should expect to remain fully invested at all times. Portfolio allocation and holdings are based upon model allocations and may change based upon an individual client’s financial situation and requirements and on market conditions and the attractiveness of individual holdings. Assessments of market strengths and weaknesses (as defined by institutional investing trends), performance of leading stocks, sector leadership and numerous other factors determine the portfolio allocation. We may analyze individual security issues and may recommend the purchase or sale of individual issues. Your investment plan contains assets in classes that we believe (based upon historical data) have attractive combinations of return, risk and correlation. Emphasis is placed on optimizing performance at the portfolio level while attempting to control risk. We use numerous publicly available sources of economic, financial and investment research. Mutual fund recommendations are based on performance reports and analysis of managers obtained from a variety of sources. Asset allocation software and historical performance modeling software may also be utilized. We do not provide accounting or legal services. While we make every effort to consider tax consequences, the sale of investments may cause taxable gain(s) or loss(es). You are encouraged to consult your tax advisor about tax consequences resulting from transactions or any particular investment held in your account. The proprietary strategies for subadvisory accounts of SpiderRock Advisors, LLC, typically involve using single stock and index options as key components, and seeking to establish optimal hedges for portfolios and concentrated positions using a variety of option strategies. For certain strategies, SpiderRock 11 Genereux Investment Management, Inc. Disclosure Brochure  Advisors, LLC will employ index or ETF Options. These “FLEX” options are customizable exchange- traded option contracts guaranteed for settlement by the Options Clearing Corporation. SpiderRock Advisors, LLC tracks a variety of portfolio risk exposures and attempts to create appropriate option-based strategies to hedge these risk exposures of the underlying portfolios. The portfolio risk is measured in real-time and the strategies are rebalanced with respect to market exposure and risks at any given time. Risk of Loss Investing in securities involves a risk of loss that clients should be prepared to bear, including loss of original principal. However, clients should be aware that past performance of any security is not necessarily indicative of future results. Therefore, no current or prospective client should assume that future performance of any specific investment or investment strategy will be profitable. We do not provide any representation or guarantee that your goals will be achieved. Investing in securities involves risk of loss. Further, depending on the different types of investments, there may be varying degrees of risk: • Market Risk. Either the market as a whole, or the value of an individual company, goes down, resulting in a decrease in the value of client investments. This is referred to as systemic risk. • Equity (Stock) Market Risk. Common stocks are susceptible to fluctuations and to volatile increases/decreases in value as their issuers’ confidence in our perceptions of the market change. Investors holding common stock (or common stock equivalents) of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer. • Company Risk. There is always a certain level of company or industry specific risk when investing in stock positions. This is referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that a company may perform poorly or that its value may be reduced based on factors specific to it or its industry (e.g., employee strike, unfavorable media attention). • Fixed Income Risk. Investing in bonds involves the risk that the issuer will default on the bond and be unable to make payments. In addition, individuals depending on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • ETF and Mutual Fund Risk. ETF and mutual fund investments bear additional expenses based on a pro-rata share of operating expenses, including potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities held by the ETF or mutual fund. Clients also incur brokerage costs when purchasing ETFs. • Management Risk. Client investments also vary with the success and failure of Advisor’s investment strategies, research, analysis and determination of portfolio securities. If Advisor’s strategies do not produce the expected returns, the value of a client’s investments will decrease. SpiderRock Advisors, LLC’s trading solutions use options, puts, calls, derivatives, and collateral instruments. Major risk factors with these strategies include: • Identification of Opportunities – SpiderRock Advisors, LLC may fail to identify and/or take advantage of profit opportunities or opportunities to hedge the portfolios or individual positions. 12 Genereux Investment Management, Inc. Disclosure Brochure  • Model and Risk - Previously successful models can become outdated or inaccurate. Correlations among portfolio instruments may change over time and could result in a loss of diversification and/or substantially more risk than the models, methods, or techniques estimated. • Hedging Risk – There is no guarantee that the investment strategies used to hedge client portfolios and/or holdings will do so and hedges could result in losses. • Illiquid Instruments - Some strategies used consist of securities and other financial instruments that are not actively and widely traded. Adverse market conditions or other factors may make it difficult to dispose of these investments resulting in a liquidity crisis (the inability to sell at expected prices). • Margin Investing – When you purchase securities, you may pay for the securities in full or borrow part of the purchase price from your account custodian or clearing firm. If you intended to borrow funds in connection with your Account, you will be required to open a margin account, which will be carried by the clearing firm. The securities purchased in such an account are the clearing firm’s collateral for its loan to you. If those securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and as a result, the brokerage firm is required to take action in order to maintain the necessary level of equity in your account. The brokerage firm may issue a margin call and/or sell other assets in your account. It is important that you fully understand the risks involved in trading securities on margin, which are applicable to any margin account that you may maintain, including any margin account that may be established as part of the services provided by SpiderRock Advisors, LLC. These risks include the following: o You can lose more funds than you deposit in your margin account. o The account custodian or clearing firm can force the sale of securities or other assets in your account. o The account custodian or clearing firm can sell your securities or other assets without contacting you. o You are not entitled to choose which securities or other assets in your margin account may be liquidated or sold to meet a margin call. o The account custodian or clearing firm may move securities held in your cash account to your margin account and pledge the transferred securities. o The account custodian or clearing firm can increase its “house” maintenance margin requirements at any time and they are not required to provide you advance written notice. o You are not entitled to an extension of time on a margin call. Margin financing is a form of indebtedness and incurs interest charges on the amount borrowed. To satisfy account obligations, position may be required to be liquidated when it is not advantageous. Losses on leveraged transactions may substantially exceed the initial investment. Unrealized losses may also be incurred which would cause the client to owe a balance. • Tax Efficient Strategies – Some investment strategies are designed to generate tax losses or dividend income taxed at favorable rates. Market conditions and tax legislation may limit the ability to execute these strategies effectively. • Structured Downside Protection Risk – Strategies designed to provide downside protection against ETF or index losses may not be available and clients may lose their entire investment. SpiderRock Advisors, LLC does not seek to provide principal protection. • Options – Options on securities may be subject to greater fluctuations in value than 13 Genereux Investment Management, Inc. Disclosure Brochure  an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. Options are not suitable for all investors. Losses can exceed the amounts invested. Call and Put options may lead to losses due to adverse movements in the price of the underlying stock, index, or other asset. The value of an option does not increase or decrease at the same rate as the underlying asset. Common risks are included in the following publication: https://www.theocc.com/about/publications/publication-listing.jsp • Futures – Options on futures may include both long and short positions. Small price movements in futures contracts may result in substantial losses and may exceed the amount invested. • Derivatives – Use of derivatives can lead to losses due to adverse movements in the price or value of the underlying asset, index, rate, or instrument. They can create investment leverage in an account and magnify the exposure to an underlying investment. Performance may not correlate as expected and hedging may not reduce portfolio risk if not sufficiently correlated to the position being hedged. Losses may exceed the initial investment. • Portfolio Turnover – High transaction costs may result in accounts that “turn over” some or all options frequently. This may also result in generating greater tax liabilities and less portfolio performance. Primary Method of Analysis or Strategy Our primary method of analysis or strategy is risk management through asset allocation. Some of the risks involved with using this method include that asset allocation may not protect your portfolio from market loss. See also, Item 4, Fees and Compensation, for additional discussion on our strategy and analysis methods when managing assets. Primarily Recommend One Type of Security We recommend any product that may be suitable for each client relative to their specific circumstances and needs, although we primarily use mutual funds, exchange traded funds, CDs and individual bonds. Item 9 – Disciplinary Information We have no legal or disciplinary events that are material to your evaluation of our business or the integrity of our management. Item 10 – Other Financial Industry Activities and Affiliations We do not have a related person that is: • A broker/dealer, municipal securities dealer or government securities dealer or broker • An investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) • An investment adviser or financial planner • A futures commission merchant, commodity pool operator or commodity trading advisor • A banking or thrift institution • Accountant or accounting firm • An insurance company or agency 14 Genereux Investment Management, Inc. Disclosure Brochure  • A lawyer or law firm • A pension consultant • A real estate broker or dealer • A sponsor or syndicator of limited partnerships. We are an independent registered investment registered advisor and only provide investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary State and federal regulations require all investment advisers to establish, maintain and enforce a Code of Ethics. We have established a Code of Ethics that applies to all of our associated persons. An investment adviser is considered a fiduciary according to state and federal regulations. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of clients at all times. We have a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle for our Code of Ethics, which also covers our insider trading, and personal securities transactions policies and procedures. We require all supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Once employed by or affiliated with us, and at least annually thereafter, all supervised persons sign an acknowledgement that they have read, understand and agree to comply with our Code of Ethics. We have the responsibility to make sure that the interests of all clients are placed ahead of our own investment interests. Full disclosure of all material facts and conflicts of interest is provided to you prior to any services being conducted. Both we and our supervised persons must conduct business in an honest, ethical and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to you. This disclosure is provided to give you a summary of our Code of Ethics. However, if clients wish to review our Code of Ethics in its entirety, a request should be directed to Mark Genereux, President and Chief Compliance Officer. Participation in Client Transactions and Personal Trading We and our representatives may buy or sell securities or have an interest or position in a security for our personal accounts that are also recommended to clients. We are and will continue to be in compliance with all state and federal regulations. At no time will we or any related person receive an added benefit or advantage over clients with respect to these transactions. As fiduciaries, neither we nor our representatives will engage in trading activity that puts our interests ahead of clients. We monitor the personal securities transactions of our supervised persons, and all applicable securities rules and regulations are strictly enforced. We do not permit and have instituted controls against insider trading. We have established a Code of Ethics (summarized above) within our internal written policies and procedures manual. Item 12 – Brokerage Practices You always have the right to accept or reject our advice. If you wish to implement our advice, you always have the right to select any broker/dealer or investment advisor you wish and are so informed. If we assist you in implementing any recommendations, we have a duty to ensure that you receive the best execution possible. Best execution does not necessarily mean the lowest price but includes the overall services received from a broker/dealer. You should understand that not all investment advisors require the use of a particular broker/dealer. While we attempt to seek best execution for client accounts, we may be unable to achieve the most 15 Genereux Investment Management, Inc. Disclosure Brochure  favorable execution of your transactions if you direct the use of a specific custodian. There may be other platforms that are less expensive and may provide faster execution capabilities. We recommend using the services of Charles Schwab as custodian for managed accounts although you are free to select any qualified custodian you wish by providing us with written direction. The decision to utilize Charles Schwab is based on the customer services provided to investors and the services available to us. While it is possible that you may occasionally pay higher commissions or transaction fees through Charles Schwab, we have determined that the company currently offers the best overall value to both us and our clients for the brokerage and technology it provides. We periodically review other alternatives that are available. However, we believe that excellent customer service and trade execution is superior to most non-service oriented, deep-discount and web-based brokers that may otherwise be available to the public. Charles Schwab features a broad line of products and services that are available to every investor, regardless of the amount of investable assets. At times, Charles Schwab may affect over-the-counter securities transactions on an agency basis. Charles Schwab executes transactions based upon a number of factors, including size of order, trading characteristics of the security, favorable execution prices, access to reliable data, availability of efficient transaction processing and possible price reductions. In filling these orders, Charles Schwab may transact with a market-making broker-dealer (“market maker”) on the other side of the trade. A market maker may mark the price of securities for which it makes a market either up or down. This cost is incurred by you along with any agency commissions assessed by Charles Schwab. Normally, best price and execution is obtained for over-the-counter securities transactions by executing directly with the market maker on a principal basis. You may incur transaction costs, in addition to any commissions charged by Charles Schwab, when trades in over-the-counter securities are affected on their behalf through that broker on an agency basis. Therefore, our election to use Charles Schwab in these situations may limit or eliminate our ability to obtain best price and execution for each transaction. The Securities and Exchange Commission requires brokerage firms to make publicly available their order routing practices via quarterly reports. The report is to provide information on routing non-directed orders (any order that you or we have not specifically instructed to be routed to a particular venue for execution). If desired, you are welcome to obtain copies of these reports from the service provider. As previously noted, you are free to use the financial service provider of your choice. If you wish to use a provider other than Charles Schwab, you must provide written instructions to us designating the selected custodian. If you direct the use of a particular broker/dealer or other custodian, we may not be able to obtain the best prices and execution for the transaction. You may receive less favorable prices than would otherwise be the case if you had not designated a particular broker/dealer or custodian. Further, you will not be able to participate in aggregate trades (i.e., block trades) and directed trades may be placed by us after effecting non-directed trades. While there is no direct link between the investment advice we give and our use of Charles Schwab, we may receive economic benefits that would not otherwise occur. We may receive traditional “non-cash benefits” or “soft dollar benefits” from Charles Schwab such as: • Customized statements • Receipt of duplicate client confirmations and bundled duplicate statements • Access to a trading desk servicing advisers exclusively • Access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts • Ability to have investment advisory fees deducted directly from client accounts • access (for a fee) to an electronic communication network for client order entry and account information • Access to mutual funds which generally require significantly high minimum initial investments or those that are otherwise only generally available to institutional investors • Reporting features • Receipt of regulatory compliance communication 16 Genereux Investment Management, Inc. Disclosure Brochure  • Discounted or free access to business-related seminars and/or products. Many of these soft dollar benefits also accrued to the benefit of many clients of Genereux Investment Management, Inc. While Charles Schwab does not directly provide any research, it may offer discounts on general products. Any research received is used for the benefit of all clients. Real-time software may be purchased through Charles Schwab or independent companies to facilitate access to account information. These soft dollar benefits received by Genereux Investment Management, Inc. create a conflict of interest; however, Genereux Investment Management, Inc, will act in your best interest. You are welcome to make inquiries about our brokerage recommendations and execution policy by directing questions to Mark A. Genereux, our President and Chief Compliance Officer. Third-party service providers may provide additional considerations such as invitations to attend industry- related conferences, seminars or workshops. We generally do not receive any consideration except for paid admission and customary meals. Trade Errors We have implemented procedures designed to prevent trade errors, although trade errors in client accounts cannot always be avoided. It is our policy to correct trade errors in a manner that is in your best interest and is also consistent with our fiduciary duty. If you cause the trade error, you are responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, you may not be able to receive any gains generated as a result of the error correction. In all situations where you do not cause the trade error, you are made whole and any loss resulting from the trade error will is absorbed by us if we caused the error. If the error is caused by the broker-dealer, then the broker-dealer will be responsible for covering all trade error costs. If an investment gain results from the correcting trade, the gain will remain in your account unless the same error involved other client account(s) that should also receive the gains. It is not permitted that all clients retain the gain. We may also confer with you to determine if you should forego the gain (e.g., due to tax reasons). We never benefit or profit from trade errors. Block Trades We may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading, or block trading and may be used when we believe such action may prove advantageous to clients. This is best illustrated in individual fixed income securities as the yield is usually higher in a larger block transaction ($1,000,000 plus) and this increased yield is shared by all of the individual clients in the transaction. If and when we aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Under this procedure, transactions are averaged as to price and are allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. If and when we determine to aggregate client orders for the purchase or sale of securities, including securities in which our associated persons may invest, we do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated persons receive any additional compensation or remuneration as a result of blocking trades 17 Genereux Investment Management, Inc. Disclosure Brochure  Item 13 – Review of Accounts Account Reviews While the calendar is the main triggering factor, reviews may also be conducted due to client request, a change in client circumstances or unusual market activity or economic conditions. Absent specific client instruction, reviews are conducted to verify the accuracy of account holdings, continued suitability of recommendations and investment products held and that the account continues to work toward client goals and objectives. Account Statements & Reports You receive an account statement at least quarterly from Charles Schwab or other qualified custodian where your account is maintained. We can provide position or performance reports to you. If requested or used in a face-to-face meeting, reports are downloaded, maintained and produced on an independent third-party provider that receives a direct data feed from our custodian. Item 14 – Client Referrals and Other Compensation Client Referrals We do not directly or indirectly compensate anyone for referring clients to us. Likewise, we do not receive any compensation for referral of clients. Other Compensation and Non-Client Economic Benefit Please see Item 12, Brokerage Practices, for discussion about the services and products we may receive from Charles Schwab. Item 15 – Custody Custody, as it applies to investment advisors, has been defined as having access or control over client funds and/or securities, but does not include the ability to execute transactions in client accounts. Custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody for purposes of the Investment Advisers Act of 1940 similar to state statutes and rules and must ensure proper procedures are implemented. It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody. We are deemed to have custody of client funds and securities whenever we are given the authority to have fees deducted directly from client accounts. Our procedures do not result in our maintaining custody of client funds and securities. For accounts where we are deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the creation of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the account statements from the qualified custodian against reports received from us. When clients have questions about their account statements, they should contact us or the qualified custodian preparing the statement. See Item 5 for additional information about custody. 18 Genereux Investment Management, Inc. Disclosure Brochure  Item 16 – Investment Discretion In addition to having trading authority on your accounts, we provide asset management services on a discretionary basis. This means we make all decisions to buy, sell or hold securities, cash or other investments in the managed account in our sole discretion without consulting with you before implementing any transactions. You must provide us with written authorization to exercise this discretionary authority. You can impose restrictions on managing your accounts. When discretionary authority is granted, it is limited. We do not have access to your funds and/or securities with the exception of having advisory fees deducted from your account by the account custodian and paid to us by the account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the account custodian. You have the ability to place reasonable restrictions on the types of investments that may be purchased in an account. You may also place reasonable limitations on the discretionary power granted to us so long as the limitations are specifically set forth or included as an attachment to the client agreement. Item 17 – Voting Client Securities We do not perform proxy-voting services on your behalf and all proxies are sent directly to you. You should read through the information provided with the proxy-voting documents and make a determination based on the information provided. If you request, we may provide limited clarifications of the issues presented in the proxy voting materials based on our understanding of issues presented in the proxy- voting materials. However, you have the ultimate responsibility for making all proxy-voting decisions. Item 18 – Financial Information We do not require or solicit prepayment of more than $500 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. Customer Privacy Policy Notice Genereux Investment Management, Inc. as a registered investment adviser, is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act, (“The Act”) and in conjunction with the SEC’s Privacy Rule (“Regulation S-P”). The privacy rules require every broker, dealer, investment company, and registered investment adviser to adopt policies and procedures reasonably designed to safeguard customer records and information. The types of information Genereux Investment Management, Inc. may collect during the normal course of business may include: • Information provided from applications, forms and provided either verbally or in writing including, but not limited to, your name, address, phone number, account information, Social Security number, employment, assets, income and debt; Information about your transactions, accounts, trading activity and parties to transactions; Information from other outside sources and; • • • Any other information that is deemed to be non-public personal information as defined by the Act and Regulation S-P. 19 Genereux Investment Management, Inc. Disclosure Brochure  Genereux Investment Management, Inc. realizes that providing personal information is an act of trust and takes the issue of protecting privacy seriously. The firm values clients’ trust and confidence and will never sell or share non-public personal information obtained from consumers or clients. All information provided by clients to the firm and information and advice furnished by the firm to clients shall be treated as confidential and shall not be disclosed to non-affiliated third parties, except as permitted by clients with written authorization, by application to facilitate the investment advisory services offered by the firm via an unaffiliated financial services provider, by client’s application to facilitate insurance services through an unaffiliated insurance company, or as required by any rule, regulation or law to which the firm or its supervised persons may be subject. The firm’s policy to protect client information extends beyond the termination of the client agreement. Client information is retained for the required time period following termination (five years) and then is safely destroyed. Genereux Investment Management, Inc. protects on-site information by limiting access to only those persons who need information to deliver the firm’s services. Genereux Investment Management, Inc. strives to only recommend financial service providers that share our privacy policies, but clients are encouraged to request other firms’ policies. Clients are encouraged to discuss any questions regarding our privacy policies and procedures directly with Mark A. Genereux, President and Chief Compliance Officer. 20 Genereux Investment Management, Inc. Disclosure Brochure