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 Matthew Kaulig. Advisor is a large Registered Investment Advisor registered with United States Securities and Exchange Commission. Our 13-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 clients to select securities and execute transactions without permission from the client prior to each transaction. 6 | P a g e 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. 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. 7 | P a g e 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. 8 | P a g e 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) 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. 9 | P a g e 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. Using the blueprint created by Kaulig Companies for the family of Matthew Kaulig, Advisor can provide the following services for family offices:  Entity formation  Office management and oversight  Investment analysis  Financial reporting  Charitable giving advice  Concierge services 10 | P a g e C. Client Tailored Services and Client Imposed Restrictions Advisor will tailor a program for the needs of each client. This will include an interview session to create an Investment Policy Statement. Advisor may use model allocations together with a specific set of recommendations for each client based on their 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 hereby 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. B. Discretionary Sub‐Advisor Authorization (“Sub‐Advised Wrap Fee Program”) ‐ Client hereby 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 hereby 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. 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. 11 | P a g e E. Assets Under Management Advisor has the following assets under management: Discretionary Amounts: Pension Consulting Services 3(38): Date Calculated: $640,530,949 $248,934,028 December 2023 Advisor has the following assets under advisement: Pension Consulting Services 3(21): Alternative Investments: Date Calculated: $197,453,640 $37,353,270 December 2023 12 | P a g e