Principal Owners Stonebridge Capital Management, Incorporated (“We”, “Us” or “Our”) has been in business since 1946 and is owned by two of its employees; Richard C. Barrett, Chief Executive Officer, President, Managing Director, Principal and Portfolio Manager and Debra L. Newman, Managing Director, Chief Financial Officer, Chief Compliance Officer. Types of Advisory Services The sole business of Stonebridge is to provide fee-based investment supervisory services to all its clients. All clients’ portfolios are managed on a discretionary basis.. We provide a broad range of investment supervisory and management services including assisting clients in setting investment objectives, establishing appropriate policy guidelines, selecting specific securities and investments, and managing portfolios on a day-to-day basis. In addition, we may work closely with clients’ other advisors on matters relating to financial, tax, estate, and retirement planning. However, we do not serve as a client’s tax advisor, legal counsel or auditor and recommend that clients consult with such other professionals as appropriate. We provide two types of portfolio management: individualized management tailored to a client’s particular investment objectives; and specialized investment strategy management. Without regard to which type of portfolio management you may select, we may invest all or a portion of your portfolio in shares of a wide variety of investment companies (“funds”) registered under the Investment Company Act of 1940, as amended (“Company Act”), including open-end funds and closed-end funds, managed by others, as long as such funds have investment objectives consistent with your stated investment objectives and are not specifically prohibited by your investment guidelines. Fees for our investment services are discussed in Item 5. Individualized Portfolio Management If you select this approach, we tailor our advisory services to your individual needs by customizing portfolios to reflect your unique investment objectives and special circumstances. With this approach, you may impose restrictions on investing in certain securities or certain types of securities. Accordingly, asset allocation and specific security selections may vary significantly among these client accounts. It is not uncommon for a security or investment to be bought or sold for one or more clients, and not for others. We encourage you to participate in the establishment and periodic review of the guidelines to be followed in managing your portfolio. While we and our clients typically agree on asset allocation guidelines, going forward we may not always be able to follow them precisely after the time of purchase due to market fluctuations or events. We view the asset allocation guidelines as targets and at times, there may be a zero allocation to a particular asset class if, based on our assessment of market conditions, a zero allocation is appropriate under the circumstances. Similarly, your portfolio may in very unusual market circumstances, hold 100% in cash. Cash in your portfolio will be swept into money- market funds by the custodian of your portfolio. Therefore, you should understand that the agreed upon asset allocation guidelines are an attempt to set desirable ranges of investing in various asset categories at time of purchase of securities, but your portfolio may not always reflect the agreed upon asset allocation guidelines. You should closely review your monthly statements, including current asset allocation, and contact us with any account-related questions. While we believe that this flexible customized approach improves the potential for successfully achieving your goals and objectives,

there are certain inherent disadvantages compared with more rigid “cookie cutter” methods. For example, because we are not implementing investment decisions simultaneously across all, or even most accounts, our opportunity to bundle buy/sell orders into larger blocks is greatly reduced. Inability to block trade may result in higher transaction costs for you than might otherwise be the case. In addition, because each account is reviewed individually, and often with prior client consultation, the timing and execution prices of portfolio transactions will vary between clients. You should carefully review the section on brokerage practices and trade allocation policy under Item 12 of this Brochure. We will manage individualized accounts on a discretionary or nondiscretionary basis. When implementing investment decisions, we usually review discretionary accounts and make portfolio changes where appropriate, prior to contacting nondiscretionary clients with the same recommendations. This methodology may result in nondiscretionary accounts underperforming discretionary accounts. At this time, all clients’ portfolios are managed on a discretionary basis. For all the foregoing reasons, performance across individualized client portfolios has significantly varied year to year and is expected to continue to vary. Please also see item #8. Types of Investments In accordance with your investment objectives, we may invest your account in exchange-listed securities, securities traded over the counter, equities of domestic issuers (both common and preferred shares), American depositary receipts representing interests in equities of foreign issuers (“ADRs”), United States government securities, warrants, corporate debt securities, commercial paper, certificates of deposit and municipal securities. We may also offer advice on private funds that invest in venture capital and on direct investments in real estate, oil and gas, and venture capital if you request such advice. We do not invest in private placements except on a nondiscretionary basis at the specific request of a client. Private funds are subject to embedded advisory fees, often including performance fees, and other expenses similar to registered funds as described above. In addition, we invest your assets in exchange traded funds (“ETFs”). An ETF is a type of closed end investment company with the investment objective of achieving the same return as a particular market index, sector, industry or commodity. Shares of an ETF are sold at current market prices in the secondary market. An ETF is similar to an index fund in that it will primarily invest in the securities of companies that are included in a selected market index. An ETF will invest in either all of the securities or a representative sample of the securities included in the index. Individual fund companies may offer a range of ETF types under one product line. Because these ETF families are constructed and operated by different fund companies, there are differences in terms of how they are made up, what indices or sectors they cover and the bogey they attempt to track. Unsupervised Assets You may hold securities or other property in your custody or brokerage accounts for which we do not provide investment advisory services (“Unsupervised Assets”). No investment advisory fee will be charged on such assets. We will have no duty, responsibility, or liability with respect to the Unsupervised Assets or any other assets not listed on the quarterly appraisal provided by us to you. Amount of Client Assets As of 12/31/2023, we had a total of $291,954,200 of client assets under management; on a discretionary basis. .