Pennington Partners & Co., LLC (“Pennington Partners”) is a limited liability company formed in January 2016 in the State of Delaware. Pennington Partners is an SEC registered investment adviser. Brian Gaister and Rodd Macklin are co-founders of Pennington Partners. Mr. Gaister is Chief Executive Officer. Guy Scott is the Chief Compliance Officer responsible for managing and monitoring the compliance program of the firm. Pennington Partners offers the following services to clients: INVESTMENT ADVISORY SERVICES Pennington Partners may provide discretionary and/or non-discretionary investment advisory services on a non-wrap fee basis. Pennington Partners’ annual investment advisory fee shall be based upon a percentage (%) of the market value and type of assets placed under Pennington Partners’ management (generally between negotiable and 1.50%) to be charged monthly in arrears. Pennington Partners’ annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, financial planning, and consulting services. In the event that the client requires extraordinary planning and/or consultation services, Pennington Partners may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. FAMILY OFFICE AND BUSINESS STRATEGY CONSULTING To the extent requested by a client, Pennington Partners provides advisory services to families and family offices focused on governance, structure, strategy, operations, succession planning, global benchmarking, and best practices. The advisory offering is priced on the project, scope of work, and is tailored to the needs of each individual families. Pennington Partners has a minimum fee of $100,000 per engagement that the firm reserves the right to evaluate on a project-by-project basis. Hourly rates range from $250 to $700, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging Pennington Partners to provide planning or consulting services on a stand-alone basis, clients are generally required to enter into a Financial Planning and Consulting Agreement with Pennington Partners setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Pennington Partners commencing services. If requested by the client, Pennington Partners may recommend the services of other professionals for implementation purposes, including certain of Pennington Partners’ representatives in their individual capacities as licensed insurance agents. (See disclosure at Item 10). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Pennington Partners. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify Pennington Partners if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/ evaluating/revising Pennington Partners’ previous recommendations and/or services. MISCELLANEOUS Non-Investment Consulting/Implementation Services. To the extent requested by the client, Pennington Partners may provide consulting services regarding non-investment related matters, such as estate planning, insurance, etc. Neither Pennington Partners, nor any of its representatives, serves as an attorney or an accountant and no portion of Pennington Partners’ services should be construed otherwise. To the extent requested by a client, Pennington Partners may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.), including certain of Pennington Partners’ representatives in their individual capacities as registered representatives and/or licensed insurance agents, as discussed below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Pennington Partners. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Private Investment Funds. Pennington Partners may provide investment advice regarding unaffiliated private investment funds and direct investment private funds sponsored by Pennington Partners. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Pennington Partners calculating its investment advisory fee. Pennington Partners’ clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Pennington Partners and/or affiliates of Pennington Partners acts as General Partner and/or investment manager to the following affiliated private investment funds, Pennington Alternative Income IDF, LP, Pennington Alternative Income Fund, LP, Pennington Appreciation Fund, LP, Pennington Liquidity Fund, LP, Pennington Private Access, LP, and Pennington Real Estate Partners OZF, LP, PTM Partners Opportunity Zone Fund I, LP, PTM Partners Opportunity Zone Fund III, LP and Atomizer LXIV, a series of Atomizer LLC (Collectively, the “Private Funds”). Pennington Partners manage the Private Funds in accordance with the objectives and investment strategies described in the applicable offering document of such Private Funds. The terms, conditions, risks, and fees pertaining to an investment in the Private Funds, are outlined in the respective Private Fund’s Private Placement Memorandum or other applicable offering documents. Our clients are under no obligation to consider or make an investment in the Private Funds. Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that Pennington Partners references private investment funds owned by the client on any supplemental account reports prepared by Pennington Partners, the value(s) for all such private investment funds shall reflect either the initial purchase and/or the most recent valuation provided by the fund sponsor. If the valuation reflects the initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. Independent Managers/Separately Managed Accounts. Pennington Partners generally recommends that clients authorize the active discretionary

management of all or a portion of their assets by and/or among certain independent investment manager(s) and/or separately managed accounts (“Independent Manager(s)”). To the extent applicable, Pennington Partners shall recommend Independent Managers consistent with the client’s investment objectives. Factors which Pennington Partners shall consider in recommending Independent Managers include the client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The specific terms and conditions under which the client engages an Independent Manager may be set forth in a separate contract between the client and the Independent Manager. Also, when required, the client shall receive a copy of the Independent Manager’s disclosure Brochure. Pennington Partners shall continue to render advisory services to the client relative to the ongoing monitoring and reviewing of account performance, for which Pennington Partners shall receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Manager. Sub-Advisory Arrangements. Pennington Partners may engage sub-advisors for the purpose of assisting with the management of its client accounts. The sub-advisor(s) shall have discretionary authority for the day-to-day management of the assets that are allocated to it by Pennington Partners. The sub-advisor shall continue in such capacity until such arrangement is terminated or modified by sub-advisor or Pennington Partners. Pennington Partners will render ongoing and continuous advisory services to the client relative to the monitoring and review of account performance, client investment objectives, and asset allocation. Pennington Partners shall pay a portion of the investment advisory fee received for these allocated assets to the sub-advisor for its sub-advisory services. Pennington Partners’ Chief Compliance Officer remains available to address any questions concerning the Registrant’s sub-advisory arrangements. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage Pennington Partners on a non-discretionary investment advisory basis must be willing to accept that Pennington Partners cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, Pennington Partners will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Use of Mutual Funds. Most mutual funds are available directly to the public. Thus, a client or prospective client can obtain many of the mutual funds that may be recommended and/or utilized by Pennington Partners independent of engaging Pennington Partners as an investment advisor. However, if a client or prospective client determines to do so, he/she/it will not receive the benefit of Pennington Partners’ initial and ongoing investment advisory services. Retirement Rollovers. A client leaving an employer typically has four options (and may engage in a combination of these options): i) leave the money in his former employer’s plan, if permitted, ii) roll over the assets to his new employer’s plan, if one is available and rollovers are permitted, iii) rollover to an IRA, or iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Pennington Partners may recommend an investor roll over plan assets to an Individual Retirement Account (IRA) managed by Pennington Partners. As a result, Pennington Partners and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave his or her plan assets with his or her old employer or roll the assets to a plan sponsored by a new employer will generally result in no compensation to Pennington Partners (unless you engage Pennington Partners to monitor and/or manage the account while maintained at your employer). Pennington Partners has an economic incentive to encourage an investor to roll plan assets into an IRA that Pennington Partners will manage or to engage Pennington Partners to monitor and/or manage the account while maintained at your employer. There are various factors that Pennington Partners may consider before recommending a rollover, including but not limited to: i) the investment options available in the plan versus the investment options available in an IRA, ii) fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan’s investment professionals versus Pennington Partners’, iv) protection of assets from creditors and legal judgments, v) required minimum distributions and age considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to rollover plan assets to an IRA managed by Pennington Partners or to engage Pennington Partners to monitor and/or manage the account while maintained at your employer. Pennington Partners’ Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above and the corresponding conflict of interest presented by such engagement. Cash Positions. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Pennington Partners may maintain cash positions for defensive purposes. All cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating Pennington Partners’ advisory fee. Please Note: When the account is holding cash positions, those cash positions will be subject to the same fee schedule as set forth below in Item 5. Pennington Partners’ Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above fee billing practice. Client Obligations. In performing its services, Pennington Partners shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Pennington Partners if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/ revising Pennington Partners’ previous recommendations and/or services. Disclosure Statement. A copy of Pennington Partners’ written Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. Pennington Partners shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Pennington Partners shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at anytime, impose reasonable restrictions, in writing, on Pennington Partners’ services. Assets Under Management As of December 31, 2023, Pennington Partners had a total of $2,973,527,798 assets under management, which included discretionary assets total $1,422,835,395 and non-discretionary assets, (including retirement accounts) total $1,550,692,403. The assets under management are calculated using the same methodology as “regulatory assets under management”.