Advisory Business Founded in March 2017, Firethorn Partners, LLC, a Delaware limited liability company (hereinafter, “Firethorn Partners” or the “Firm”) is an investment advisor registered with the U.S. Securities and Exchange Commission (the “SEC”). The Firm provides investment management services to its Clients (individually, the “Client”). This Brochure is not: a) an offer or agreement to provide advisory services to any person, b) an offer to sell interests (or a solicitation of an offer to purchase interests) in any investment fund, or c) a complete discussion of the features, risks or conflicts associated with any investment fund, or any other product or service offered by Firethorn Partners. Firethorn Partners is owned by Mr. Sanders, Mr. Rhemtulla, Mr. Bains, and Mr. Tomicic. Mr. Bains’ beneficial ownership is held through a Canadian corporation, Cadogan Park Advisors Inc. (“Cadogan Park”) and Bayswater Partners LLC. Mr. Tomicic’s beneficial ownership is held through Martom Holdings LLC. Firethorn Partners operates in the US through its management office in Houston and an investment office in Vancouver, providing investment advisory services to US domiciled clients. Cadogan Park is a Canadian based investment adviser registered with each of the following Securities Commissions: Alberta, British Columbia, Ontario, and New Brunswick. Cadogan Park provides investment advisory services to Canadian domiciled clients and expats. Clients may engage one or both of Firethorn Partners and Cadogan Park to fulfill their investment mandates depending on the specific personal circumstances and tax residency. Both Firethorn Partners and Cadogan Park are registered with the SEC under the Investment Advisers Act of 1940 (“Advisers Act”) and share personnel and office space at their principal place of business in Vancouver, BC. Registration as an investment adviser, or any reference to the Firms being “registered” does not imply a certain level of skill or training. Firethorn Partners engages in specialized services that may appeal to expatriate individuals or those individuals that reside in one jurisdiction while they continue to have assets in another jurisdiction (cross border services). Firethorn Partners’ activities with respect to non-U.S. clients may differ from those described generally herein and Firethorn Partners or its affiliate, Cadogan Park, may provide additional or different services to non-U.S. clients. Furthermore, any discussion of activities with respect to non-U.S. clients is intended solely to provide recipients a more complete understanding of Firethorn Partners’ business, including potential conflicts of interest. Firethorn Partners provides investment advisory services. Investment decisions are based upon each client’s Investment Policy Statement (IPS). The assessment of a client’s risk and return objectives is achieved through the completion of the client’s personal profile questionnaire, including the client’s personal financial situation, investment objectives and risk tolerance. This information combined with any input from the client’s other professional advisors, is then finalized in a mutually agreed IPS. The client’s assets are then invested in accordance with the guidelines defined in the IPS, which may also indicate the eligible investments to be used to achieve the portfolio’s investment mandate. Firethorn Partners may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among independent investment managers (Sub-Advisors) in accordance with the client’s designated investment objective(s). In such situations, the Sub-Advisors shall have day-to-day responsibility for the active discretionary management of the allocated assets. Firethorn Partners shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which 5 | P a g e Firethorn Partners shall consider in recommending Sub-Advisor(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. In addition to the IPS, each client will formally agree to engage the services of Firethorn Partners through an Investment Management Agreement (IMA). This document includes information on the client’s identity and personal financial situation. It is the responsibility of the client to keep Firethorn Partners updated on an ongoing basis with respect to any information contained in the IMA, including any significant changes to their personal or financial situation that could impact the appropriateness of the client’s IPS. Investment Advisory Services A Personal Strategy is a comprehensive investment portfolio. It is focused on achieving the client’s financial goals and is designed to grow with the client over time. Portfolios in a Personal Strategy are custom designed and are flexible to meet the Client’s needs or wants. Personal Strategy asset allocations go beyond basic stock and bond portfolios. They invest globally, primarily utilizing individual equities and exchange traded funds. Our unique tactical index weighting approach

adds further diversification and potential return by ensuring exposure to all areas of the market while avoiding being overweight to high-risk segments. Firethorn Partners believes that asset allocation is the most important investment decision. The goal-based nature of a Personal Strategy means the Client’s asset allocation is continuously linked to their evolving situation, thereby maximizing the likelihood of long- term success. A. Firethorn Partners conducts an initial client review gathering personal information and a profile questionnaire. B. Firethorn Partners utilizes information provided by the client and that of their other professional advisors, and then prepare an IPS. C. Firethorn Partners presents investment recommendations to each prospective client as aligned with their IPS. D. Firethorn Partners implements portfolios on a discretionary basis and may take into consideration recommendations or specifications provided by the client but are under no obligation to fulfill such requests. E. The client is free to choose a customized investment portfolio solution or one of three model portfolios: i. BALANCED (Equities – 55%; Fixed Income – 37%; Cash – 8%) ii. GROWTH (Equities – 70%; Fixed income – 25%; Cash – 5%) iii. ALL EQUITY (Equity – 95%; Cash – 5%) F. Portfolio Rebalancing within these models may occur 3 times per year. i. CUSTOM (Equity – 60%; Fixed Income – 20%; Cash – 7%; Currencies – 5%; Alternative – 8%) G. There is no Automatic re-balancing on custom portfolios. H. Custom and Model portfolios are managed on a discretionary basis. 6 | P a g e
• Ongoing discretionary investment management
• Automatic MODEL portfolio rebalancing
• Tax optimization and tax loss harvesting, as applicable
• Portfolio personalization, as applicable
• Financial planning
• Assigned personal financial advisor
• Unaffiliated, qualified custodian used
• U.S. and Canada cross border portfolio planning as applicable.
IRA Rollover Recommendations For the purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020- 02"), when applicable, we are providing the following acknowledgment to clients. When Firethorn Partners provides investment advice to clients regarding their retirement plan account or individual retirement account, Firethorn Partners 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. The way Firethorn Partners makes money creates some conflicts with client interests. Firethorn Partners operates under an exemption that requires Firethorn Partners to act in the clients’ best interest and not put Firethorn Partners’ or Firethorn Partners’ employees’ interests ahead of the clients. Under this exemption, Firethorn Partners must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put Firethorn Partners’ or Firethorn Partners’ employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that Firethorn Partners and Firethorn Partners’ employees give advice that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. Firethorn Partners benefits financially from the rollover of the clients’ assets from a retirement account to an account that Firethorn Partners manages or provides investment advice, because the assets increase Firethorn Partners’ assets under management and, in turn, Firethorn Partners’ advisory fees. As a fiduciary, Firethorn Partners only recommends a rollover when Firethorn Partners and Firethorn Partners’ employees believe it is in the clients’ best interest. Pooled Investment Vehicles Firethorn Partners serves as the general partner of the General Partner and the manager of the Investment Manager for the Firethorn Opportunity Fund I, LP (the “Fund”). The Fund’s objectives is to achieve capital appreciation through long and short investments in U.S. equities. The Fund is exempt from registration pursuant to Rule 506(b) of the Securities Act of 1933 and relies on an exemption from the investment Company Act of 1940 under 3(c)-1. Investments in Fund are deemed to be high risk investments and for that reason, the offerings are available only to accredited investors, who can bear the risk of loss of their investment. This Disclosure Brochure provides only a broad summary of the information provided in the offering documents. Investors should refer to the specific Fund Offering Document for definitive and more comprehensive information regarding a specific investment concept and the matters described in this Brochure. 7 | P a g e Assets Under Management ASSETS UNDER MANAGEMENT: Firethorn Partners has $21,731,909 regulatory assets under management on a discretionary basis as of December 31, 2023. 8 | P a g e