Energy Opportunities Capital Management, LLC

Energy Opportunities Capital Management, LLC, established in 2008, specializes in managing investment advisory accounts focused on the energy industry. The firm offers three investment strategies — Energy Opportunities Original, Energy Opportunities Energy Dynamics, and Energy Opportunities Tactical Growth — all investing solely in publicly traded equities. Services are provided on a percentage of assets under management basis. The firm does not offer wrap fee programs and maintains a minimum client account size of $2 million, which may be negotiable. EOCM does not recommend specific custodians but ensures client assets are held separately in custodial accounts. As of December 31, 2022, EOCM managed $36,959,292 in assets for 10 accounts on a discretionary basis. The firm charges an annual fee of 1.00% of the market value of the account, paid quarterly in arrears, with negotiable fees under certain circumstances. EOCM is a fiduciary to ERISA accounts, subject to specific duties and obligations. The firm does not engage in principal or agency cross transactions and does not vote proxies unless agreed upon with the client. EOCM maintains strict compliance with ethical standards and federal securities laws, with a Code of Business Conduct and Ethics in place. The firm discloses potential conflicts of interest, including soft dollar arrangements and directed brokerage practices. EOCM conducts quarterly reviews of client portfolios and has no financial conditions impairing its ability to meet obligations.