JM2 CAPITAL INC.

Item 1 – Cover Page JM2 Capital Inc. 16340 Muirfield Place Edmond, OK 73013 (405) 285-2878 https://jm2capital.com/ March 5, 2025 This Brochure provides information about the qualifications and business practices of JM2 Capital Inc. (“JM2 Capital”, “us”, “we”, “our”). If you have any questions about the contents of this Brochure, please contact us at (405) 285-2878 or via email at cturner@jm2capital.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about JM2 Capital is also available via the SEC’s website www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for JM2 Capital is 292351. The SEC’s web site also provides information about any persons affiliated with JM2 Capital who are registered, or are required to be registered, as Investment Adviser Representatives of JM2 Capital. JM2 Capital is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information that you may use to determine whether to hire or retain them. JM2 Capital ADV Part 2A Page 1 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  Item 2 – Material Changes Material Changes since the initial Brochure: Since our last annual update, dated February 1, 2024, we have made no material changes. We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 90 days of the close of our business’ fiscal year end which is December 31st. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you with information on how to obtain the complete brochure. Currently, our Brochure may be requested at any time, without charge, by contacting Cameron Turner at (405) 285-2878. JM2 Capital ADV Part 2A Page 2 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  Item 3 – Table of Contents Item 1 – Cover Page ...........................................................................................................................1 Item 2 – Material Changes ..................................................................................................................2 Item 3 – Table of Contents .................................................................................................................3 Item 4 – Advisory Business Introduction .............................................................................................4 Item 5 – Fees and Compensation ........................................................................................................6 Item 6 – Performance Based Fee and Side by Side Management .........................................................7 Item 7 – Types of Client(s) ..................................................................................................................7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................8 Item 9 – Disciplinary Information ..................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ............................................................. 12 Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading ................ 13 Item 12 – Brokerage Practices .......................................................................................................... 14 Item 13 – Review of Accounts ........................................................................................................... 17 Item 14 – Client Referrals and Other Compensation .......................................................................... 18 Item 15 – Custody ............................................................................................................................ 18 Item 16 – Investment Discretion ....................................................................................................... 19 Item 17 – Voting Client Securities ..................................................................................................... 19 Item 18 – Financial Information ........................................................................................................ 20 JM2 Capital ADV Part 2A Page 3 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  Item 4 – Advisory Business Introduction Our Advisory Business JM2 Capital Inc. has applied for registration with the Securities and Exchange Commission (SEC). The Adviser was founded in 2018 by John Mathena, who is the Adviser’s principal owner. Cameron Turner serves as the firm’s Chief Compliance Officer and Chief Investment Officer. Services JM2 Capital offers asset management and financial planning services, with an emphasis on building portfolios designed to meet the needs of our clients. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. Active Asset Management Tailored Asset Management Services As part of the active asset management process we will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and tailor a portfolio with appropriate asset allocations and investment strategy[ies]. Our recommendations and ongoing management are based upon your investment goals, objectives and risk tolerance. We will monitor the account, trade as necessary, and communicate regularly with you. We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with questions about your account. We will also provide financial planning services with your ongoing asset management. In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. * Please note that pursuant to the investment advisory agreement you are obligated to notify us promptly when your financial situation, goals, objectives, or needs change. * You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request. JM2 Capital ADV Part 2A Page 4 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. Additionally, trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Periodically, your account will most likely need to be rebalanced or reallocated in order to reestablish the targeted percentages of your initial asset allocation. The firm aims to rebalance accounts at least semi- annually. However, we shall rebalance accounts more frequently if needed, which is typically suitable after distributions and contributions. You will be responsible for all tax consequences resulting from the sale of any security, rebalancing or reallocation of the account. You are responsible for any taxable events in these instances. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, itemize all transaction activity, and list the types, amounts, and total value of securities held. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. We may also provide you with quarterly performance statements. These statements give you additional feedback regarding performance, educate you about our long-term investment philosophy, and describe any changes in current strategy and allocation along with the reasons for making these changes. Third-Party Money Manager We may determine that opening an account with a professional third-party money manager is in your best interest. We may have third-party money manager relationships with several third-party advisory firms. Our third-party money managers provide investment research and discretionary assets allocation for certain clients for whom we believe these services to be in their best interest. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by you. Due to the nature of these programs, each of the independent money managers is obligated to provide you with a separate disclosure document. You should carefully review this document for important and specific program details, including pricing. Under these programs, we shall: • Assist in the identification of investment objectives • Recommend specific investment style and asset allocation strategies • Review performance and progress JM2 Capital ADV Part 2A Page 5 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  • Recommend reallocation among managers or styles within the program • Recommend the hiring and firing of subadvisors You should read the ADV Part 2 disclosure document of subadvisor for complete details. Wrap Fee The Adviser does not sponsor or participate in a third-party sponsored wrap fee program. Assets Under Management As of the December 31, 2024, we have $186,431,370 in discretionary assets under management. Item 5 – Fees and Compensation Asset Management Fee Schedule The minimum account opening balance is $500,000, which may be negotiable based upon certain circumstances and at the Adviser’s discretion. The fee charged is based upon the amount of money invested. Multiple accounts of immediately-related family members, at the same mailing address, may be considered one consolidated account for billing purposes. Fees are charged monthly, in arrears. Payments are due and will be assessed on the last day of each month, based on the previous month ending balance of the account(s) under management for the preceding month. The Adviser will not pro rate for deposits and withdrawals in the account during the billing period. Fees will be calculated as follows: Tiered fee Schedule AUM Fee First $1,000,000 1.0% Over $1,000,000 0.50% The fees shown above are annual fees and may be negotiable based upon certain circumstances. No increase in the annual fee shall be effective without prior written notification. JM2 Capital believes the advisory fee is reasonable considering the fees charged by other investment advisers offering similar services/programs. Clients who utilize the services of a Third-Party Money Manager shall be charged a separate management by the Third-Party Manager. This fee shall vary depending on the Client’s agreement with the Third-Party Manager. This fee will be separate from, and in addition to, the management fees charged by JM2 fees shown above. Please review the Third-Party Money Manager’s ADV Part 2A for additional details regarding their fees. JM2 Capital ADV Part 2A Page 6 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  The Client acknowledges and agrees that the Adviser may charge for certain additional Assets managed for the Client by the Adviser, but not held by the Custodian (i.e. variable annuities, mutual funds, 401(k), and variable life). Automatic Payment of Fee The Client agrees to authorize the Custodian to deduct advisory fees directly from client accounts and to pay directly to JM2 Capital upon receipt of notice the Account's investment advisory services fee. Fee withdrawals will occur no more frequently than monthly from the Client's Account, unless specifically instructed otherwise by the Client. The Custodian will send to the Client a statement, at least quarterly, indicating all amounts disbursed from the Account, including the fee paid directly to JM2 Capital. JM2 Capital's access to the Assets of the Account will be limited to trading and the withdrawals authorized above. Third Party Fees Our fees do not include brokerage commissions, transaction fees, and other related costs and expenses. You may incur certain charges imposed by custodians, third party investment companies and other third parties. These include fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, money market funds and exchange-traded funds (ETFs) also charge internal management fees, which are disclosed in the fund’s prospectus. These fees may include, but are not limited to, a management fee, upfront sales charges, and other fund expenses. Certain strategies offered by us may involve investment in mutual funds and/or ETFs. Load and no load mutual funds may pay annual distribution charges, sometimes referred to as “12(b)(1) fees”. These 12(b)(1) fees come from fund assets, and thus indirectly from clients’ assets. We do not receive any compensation from these fees. All of these fees are in addition to the management fee you pay us. You should review all fees charged to fully understand the total amount of fees you will pay. Services similar to those offered by us may be available elsewhere for more or less than the amounts we charge. Our brokerage practices are discussed in more detail under Item 12 – Brokerage Practices. Item 6 – Performance Based Fee and Side by Side Management We do not charge any performance-based fees. These are fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 – Types of Client(s) We provide investment advisory services to individuals, trusts, estates, charitable organizations, corporations and other business entities. JM2 Capital ADV Part 2A Page 7 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  Our minimum account opening balance is $500,000, which may be negotiable based upon certain circumstances. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We use Fundamental and Technical Analysis as part of our overall investment management discipline; the implementation of these analyses as part of our investment advisory services to you may include any, all or a combination of the following: Fundamental Analysis Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the underlying factors that affect a company's actual business and its future prospects. Fundamental analysis is about using real data to evaluate a security's value. It refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. The end goal of performing fundamental analysis is to produce a value that we can compare with the security's current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Technical Analysis Technical Analysis is a technique that attempts to determine a security’s value by developing models and trading rules based upon price and volume transformation. Technical analysis assumes that a market’s price reflects all relevant information so the analysis focuses on the history of a security’s trading behavior rather than external drivers such as economic, fundamental and news events. The practice of technical analysis incorporates the importance of understanding how market participants perceive and act upon relevant information rather than focusing on the information itself. Ultimately, technical analysts develop trading models and rules by evaluating factors such as market trends, market participant behaviors, supply and demand and pricing patterns and correlations. As with other types of analysis, the predictive nature of technical analysis can vary greatly; models and rules are often modified and updated as new patterns and behaviors develop. Past performance is not an indicator of future return. Investment Strategies In order to perform this analysis, we use many resources, such as: • Morningstar • Financial newspapers and magazines (e.g. Wall Street Journal, Forbes, etc.) • Annual reports, prospectuses, filings • Company press releases and websites • Research materials prepared by third parties JM2 Capital ADV Part 2A Page 8 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  The investment strategies we use to implement any investment advice given to you include, but are not limited to: • Long term purchases -securities held at least a year Risk of Loss We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to bear. You need to understand that investment decisions made for your account by us are subject to various market, currency, economic, political and business risks. The investment decisions we make for you will not always be profitable nor can we guarantee any level of performance. A list of all risks associated with the strategies, products and methodology we offer are listed below: Alternative Investment Risk Investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • Loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices • Lack of liquidity in that there may be no secondary market for the fund and none expected to develop • Volatility of returns • Absence of information regarding valuations and pricing • Delays in tax reporting • Less regulation and higher fees than mutual funds. Bond Fund Risk Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields of the risks associated with bond funds include: • Call Risk - the possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-yielding bond before the bond's maturity date. • Credit Risk - the possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally will be subject to higher risk. • Interest Rate Risk - the risk that the market value of the bonds will go down when interest rates go up. Because of this, you can lose money in any bond fund, including those that invest only in insured bonds or Treasury bonds. JM2 Capital ADV Part 2A Page 9 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  • Prepayment Risk — the chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or "retire") its debt and issue new bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield. Fundamental Analysis Risk Fundamental analysis, when used in isolation, has a number of risks: • There are an infinite number of factors that can affect the earnings of a company, and its stock price, over time. These can include economic, political and social factors, in addition to the various company statistics. • The data used may be out of date. • It is difficult to give appropriate weightings to the factors. • It assumes that the analyst is competent. • It ignores the influence of random events such as oil spills, product defects being exposed, and acts of God and so on. Exchange Traded Fund (“ETF”) Risk Most ETFs are passively managed investment companies whose shares are purchased and sold on a securities exchange. An ETF represents a portfolio of securities designed to track a particular market segment or index. ETFs are subject to the following risks that do not apply to conventional funds: • The market price of the ETF’s shares may trade at a premium or a discount to their net asset value; • An active trading market for an ETF’s shares may not develop or be maintained; and • There is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged Key Person Risk JM2 Capital is a small business. Consequently, the loss of any of our key personnel, including Cameron Turner and Casey Morford would negatively impact our ability to manage your assets. We have a Business Continuity Plan in place to address the loss of key personnel. Should we lose all key personnel, you shall be instructed by whatever means available to use given the circumstances of the event to either 1) acquire another financial advisor, 2) manage your assets independently or 3) liquidate your account. Mutual Funds Risk The following is a list of some general risks associated with investing in mutual funds. • Country Risk - The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline. JM2 Capital ADV Part 2A Page 10 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  • Currency Risk -The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk. • Income Risk - The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates. • Industry Risk - The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. • Inflation Risk - The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-adjusted returns. • Manager Risk -The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives. • Market Risk -The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk -The possibility that an investment will go down in value, or "lose money," from the original or invested amount. Stock Fund Risk Overall "market risk" poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such as the overall strength of the economy or demand for particular products or services. Technical Analysis risk • Technical analysis is derived from the study of market participant behavior and its efficacy is a matter of controversy. • Methods vary greatly and can be highly subjective; different technical analysts can sometimes make contradictory predictions from the same data. • Models and rules can incur sufficiently high transaction costs. Overall Risks Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. You may lose some or all of the money you invest, including your principal, because the securities held by a fund goes up and down in value. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change. Before you invest, be sure to read a fund's prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals. While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. JM2 Capital ADV Part 2A Page 11 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  If you'll need your money to meet a financial goal in the near-term, you probably can't afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market. Item 9 – Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We do not have any information to disclose concerning JM2 Capital or any of our IARs. We adhere to high ethical standards for all IARs and associates. Item 10 – Other Financial Industry Activities and Affiliations Neither JM2 Capital nor any of its management persons are registered as a broker-dealer or registered as a representative of a broker-dealer, nor does it have any pending application to register. In addition, neither JM2 Capital nor its management persons are affiliated with any broker-dealer. JM2 Capital and its management persons are not registering as a commodity pool operator, futures commission merchant, or commodity trading advisor. Other Financial Industry Affiliations In addition to providing the advisory services detailed in Item 4, JM2 Capital also provides family office services to Mathena Investments, an entity which is owned by John Mathena, his siblings and his parents. John and Elizabeth Mathena are owners of JM2 Capital. Family office services are not currently available to advisory clients of JM2 Capital. Cameron Turner devotes approximately 10% of his time to his activity and Casey Morford devotes approximately 20% of her time to this activity. While this poses an inherent conflict of interest to place the interests of Mathena Investments ahead of other clients, Cameron Turner (our CCO) monitors all transactions to ensure that JM2 Capital does not place the interests of JM2 Capital or Mathena Investments ahead of the interests of our clients. We respect our fiduciary duty to you and place the interests of our clients first. Prior to the founding of JM2 Capital’s RIA, Cameron Turner, CPA, provided tax preparation services to a local family and business owners for a fee. Providing such services to current clients presents an inherent conflict of interest. However, there is no intention to offer tax preparation services to JM2 Capital clients or to any additional individuals outside the firm with whom Cameron Turner does not have an existing relationship to provide such services. All tax preparation work and related client meetings are conducted strictly outside of JM2 Capital’s business hours. JM2 Capital ADV Part 2A Page 12 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  JM2 Capital also provides business consulting services. None of our Investment Adviser Representatives participate in our business consulting services, but an inherent conflict of interest exists as we are incentivized to recommend those services. We may recommend those services to clients who are business owners if we believe that such services may benefit the interests of the client. To mitigate this conflict, we require that all Investment Adviser Representatives disclose this conflict to clients at or before the time of the recommendation. Furthermore, we also require representatives to disclose that clients are free to purchase recommended products and services from providers not affiliated with us. Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading General Information We have adopted a Code of Ethics for all IARs of the firm describing its high standards of business conduct and fiduciary duty to you, our client. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All of our IARs must acknowledge the terms of the Code of Ethics annually, or as amended. Participation or Interest in Client Accounts Our Compliance policies and procedures prohibit anyone associated with JM2 Capital from having an interest in a client account or participating in the profits of a client’s account without the approval of the CCO. The following acts are prohibited: • Employing any device, scheme or artifice to defraud • Making any untrue statement of a material fact • Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading • Engaging in any fraudulent or deceitful act, practice or course of business • Engaging in any manipulative practices Clients and prospective clients may request a copy of the firm's Code of Ethics by contacting the CCO. Personal Trading We may recommend securities to you that we will purchase for our own accounts. We may trade securities in our account that we have recommended to you as long as we place our orders at the same time as your orders on an aggregated basis when consistent with our obligation of best execution. This policy is meant to prevent us from benefiting as a result of transactions placed on behalf of advisory accounts. When trades are aggregated, all parties will share the costs in proportion to their investment. We will retain records of the trade Order (specifying each participating account) and its allocation. Completed Orders will be allocated as specified in the initial trade order. Partially filled Orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. JM2 Capital ADV Part 2A Page 13 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  JM2 Capital has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of “Access Persons”. The policy requires that an Access Person of the firm provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person’s current securities holdings at least once each twelve (12) month period thereafter on a date the Adviser selects; however, provided that at any time that the Adviser has only one Access Person, he or she shall not be required to submit any securities report described above. We have established the following restrictions in order to ensure our fiduciary responsibilities regarding insider trading are met: • No securities for our personal portfolio(s) shall be bought or sold where this decision is substantially derived, in whole or in part, from the role of IARs of JM2 Capital, unless the information is also available to the investing public on reasonable inquiry. In no case, shall we put our own interests ahead of yours. Privacy Statement We are committed to safeguarding your confidential information and hold all personal information provided to us in the strictest confidence. These records include all personal information that we collect from you or receive from other firms in connection with any of the financial services they provide. We also require other firms with whom we deal with to restrict the use of your information. Our Privacy Policy is available upon request. Conflicts of Interest JM2 Capital’s IARs may employ the same strategy for their personal investment accounts as it does for its clients. However, IARs may not place their orders in a way to benefit from the purchase or sale of a security. We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interests of all the accounts we advise. Item 12 – Brokerage Practices Factors Used to Select Custodians In recommending a custodian/broker-dealer, we look for a company that offers relatively low transaction fees, access to desired securities, trading platforms, and support services. We may recommend clients use Charles Schwab & Co., Inc. (“Schwab”) as the qualified custodian for their accounts when utilizing our asset management services. JM2 Capital ADV Part 2A Page 14 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  Soft Dollars Schwab may provide us with certain brokerage and research products and services that qualify as "brokerage or research services" under the rules. These research products and/or services will assist the IAR in its investment decision making process. Such research generally will be used to service all of the IAR’s clients, but brokerage commissions paid by the client may be used to pay for research that is not used in managing the client’s account. The account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to affect the same transaction where the IAR determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Because soft dollar benefits could be considered to provide a benefit to the adviser that might cause the client to pay more than the lowest available commission without receiving the most benefit, they are considered a conflict of interest in recommending or directing custodial and third-party managerial services. JM2 Capital mitigates these conflicts of interest through strong oversight of soft-dollar arrangements by the Chief Compliance Officer, in order to assure the soft dollar benefits serve the best interests of the client. There may other benefits from recommending Schwab or other third party managers such as software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Other services may include, but are not limited to, performance reporting, financial planning, contact management systems, third party research, publications, access to educational conferences, roundtables and webinars, practice management resources, access to consultants and other third-party service providers who provide a wide array of business related services and technology with whom JM2 Capital may contract directly. JM2 Capital may receive seminar expense reimbursements from product sponsors which may be based on the sales of products to their clients. Soft dollar benefits may be proportionally allocated to any accounts that may generate different amounts of the soft dollar benefits. Economic Benefits JM2 Capital may recommend/require that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of the Advisor’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. JM2 Capital is independently owned and operated and not affiliated with Schwab. Schwab provides JM2 Capital with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in JM2 Capital ADV Part 2A Page 15 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For JM2 Capital client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction- related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. JM2 Capital endeavors to act its clients’ best interests, Schwab also makes available to JM2 Capital other products and services that benefit JM2 Capital but may not benefit its clients’ accounts. These benefits may include national, regional or JM2 Capital specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of JM2 Capital by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist JM2 Capital in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of JM2 Capital’s fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of JM2 Capital’s accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to JM2 Capital other services intended to help JM2 Capital manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to JM2 Capital by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to JM2 Capital. While, as a fiduciary, JM2 Capital’s in recommendation/requirement that clients maintain their assets in accounts at Schwab may be based in part on the benefit to JM2 Capital of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Best Execution We have an obligation to seek best execution for you. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, reputation and responsiveness. Therefore, we will seek competitive commission rates, but we may not obtain the lowest possible commission rates for account transactions. JM2 Capital ADV Part 2A Page 16 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  Brokerage for Client Referrals In selecting and/or recommending broker-dealers, we do not take into consideration whether or not we will receive client referrals from the broker-dealer or third party. Directed Brokerage We do not permit directed brokerage. We will require you to use the custodian of our choosing as the custodial firm. Trading Transactions for each client account generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may (but are not obligated to) combine or “batch” such Orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. Under this procedure, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. However, this may increase risk that includes, but is not necessarily limited to, delayed executions that may cause differences in prices among client accounts held within the same block. Item 13 – Review of Accounts Reviews Reviews are conducted at least annually or as agreed to by us. Reviews will be conducted by our Chief Compliance Officer, Cameron Turner. JM2 Capital monitors Client portfolios on a continuous and ongoing basis. The accounts will be monitored to ensure that the investment plan continues to be implemented in a manner which matches your objectives and risk tolerances. All Clients are encouraged to discuss their needs, goals and objectives with JM2 Capital and to keep the Advisor informed of any changes thereto. Significant market events affecting the price of one or more securities in client’s accounts, changes in the investment objectives or guidelines of a particular client, or specific arrangements with particular clients may trigger reviews of client accounts on an immediate basis. Reports Unless otherwise agreed upon, Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, Clients may also receive written or electronic reports from JM2 Capital which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from JM2 Capital. JM2 Capital ADV Part 2A Page 17 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  Item 14 – Client Referrals and Other Compensation We do not receive any economic benefit from someone who is not a client for providing investment advice or other advisory services to our clients nor do we directly or indirectly pay any compensation to another person if they refer clients to us. Item 15 – Custody We do not have physical custody of any accounts or assets. However, we may be deemed to have custody of your account(s) if we have the ability to deduct your advisory fees from the custodian. We use Schawb as the custodian and/or broker-dealer for all your accounts. You should receive at least quarterly statements from the broker-dealer or custodian that holds and maintains your investment assets. We urge you to carefully review such statements. We do not debit the client fees directly from your advisory account. We send information to your custodian to debit your fees and to pay them to us. You authorized the custodian to pay us directly at the onset of the relationship. Under government regulations, we are deemed to have custody of your assets if you authorize us to instruct Schwab to deduct our advisory fees directly from your account. Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least quarterly. They will be sent to the email or postal mailing address you provided to Schwab. You should carefully review those statements promptly when you receive them. We also urge you to compare Schwab’s account statements to the periodic account statements you will receive from us. Standing Letter of Authorization JM2 Capital is deemed to have custody of client funds or securities as a result of maintaining standing letters of authorization (SLOA) for the purpose of distributing funds from a client’s account. For those accounts in which we have the ability to initiate distributions from a client’s account, via journal, ACH or wire to a third-party, which is an account held in the name of someone other than the client, we will ensure the following conditions have been met in order for us to be in compliance with SEC and State Custody Rules and ensure the safe keeping of our client’s funds: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third-party’s name, and either the third-party’s address or the third-party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third-party either on a specified schedule or from time to time. JM2 Capital ADV Part 2A Page 18 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third- party, the address, or any other information about the third-party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third-party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16 – Investment Discretion We manage assets on a discretionary basis. When you provide discretion authority, which will be evidenced via the written, discretionary agreement between the client and the Adviser, we will have the authority to determine the following without your consent: • Securities to be bought or sold for your account • Amount of securities to be bought or sold for your account In all cases this discretion is exercised in a manner consistent with your stated investment objectives for your account and in accordance with any restrictions placed on the account(s). When active asset management services are provided on a discretionary basis the client will enter into a separate custodial agreement with the custodian. The custodian agreement will include a limited power of attorney to trade in the client’s account(s) which authorizes the custodian to take instructions from us regarding all investment decisions for your account. If utilizing the services of a third-party money manager, the third-party money manager and/or custodians may have discretion over your account. The Advisory Agreement and ADV Part 2 of the third-party money manager and the custodial new account documentation will detail this in full. Item 17 – Voting Client Securities As a matter of firm policy and practice, we do not have any authority to and do not vote proxies on behalf of advisory clients. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. We may provide advice to you regarding your voting of proxies. The JM2 Capital ADV Part 2A Page 19 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC  custodian will forward you copies of all proxies and shareholder communications relating to your account assets. Item 18 – Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that would impair our ability to meet any contractual and fiduciary commitments to you, our client. We have not been the subject of any bankruptcy proceedings. In no event shall we charge advisory fees that are both in excess of five hundred dollars and more than six months in advance of advisory services rendered. On April 14, 2020, the firm received a Paycheck Protection Plan Loan through the SBA in conjunction with the relief afforded from the CARES Act. The firm used the PPP to continue payroll for the firm’s employees and the firm did not suffer any interruption of service. JM2 Capital ADV Part 2A Page 20 of 20 February 25 © 2010 – 2024 Red Oak Compliance Solutions LLC