Marathon Capital, LLC and each of its wholly-owned subsidiaries, including Marathon Capital Markets, LLC and Marathon Capital, Ltd (collectively, “Marathon Capital” or the “Firm”), maintain a Business Continuity Plan (the “Plan”) that addresses how Marathon Capital will respond to events that may significantly interrupt its business. Each regulated entity may maintain its own Plan in accordance with applicable regulatory and legal requirements. Since the timing and impact of disasters and disruptions is unpredictable, Marathon Capital will aim to be flexible in its approach to respond to business disruptions. With that in mind, this document provides a summary of the Plan.

Marathon Capital’s policy is to respond to a business interruption by ensuring employee safety, safeguarding firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting Marathon Capital’s books and records, and allowing customers to resume business transactions. In the event Marathon Capital determines it is unable to continue its business, it will take the necessary steps to ensure its customers have quick access to Firm employees and existing engagements.

In that regard, the goals of the Plan are to:

• Understand and incorporate business priorities into business continuity practices.
• Incorporate relevant regulations into business continuity practices.
• Prepare for events or scenarios that impact Marathon Capital’s primary place of business, critical systems and infrastructure, or related disaster recovery processes.
• Implement appropriate strategies for executing recovery of critical systems.
• Provide alternative and emergency response notification and communication measures for Marathon Capital related critical parties in the event of a business disruption.
• Improve responsiveness by employees in times of disaster to help ensure that all aspects of primary facilities, backup sites, people, processes, hardware, software, communication, and legal responsibilities are accounted for.
• Provide business process availability to all employees from remote locations without any significant business impact.

Business interruptions can vary in scope. They may impact just the office location(s) or an entire city or larger geographic area. In all such situations, Marathon Capital seeks to continue business operations and notify all important stakeholders of how to contact Marathon Capital employees via several means including, but not limited to, telephone, fax, email, or via Marathon Capital’s website (marathoncapital.com). Based on a company-wide risk analysis, Marathon Capital has put in place a Plan that helps in response and recovery measures during business interruptions and includes the following elements:

• Data backup and recovery of all mission critical systems
• Alternative communication methods with employees, third-party vendors, suppliers, banks, counterparties, and regulators, including re-routing of critical communication mechanisms
• Capability to work from home or other locations outside of the primary offices
• Employee preparedness training including disaster testing and recovery
• Regulatory reporting and communication
• Critical business constituents and third-party impact
• At a minimum, an annual review and/or maintenance of our plan

While Marathon Capital cannot eliminate all risks of interruption, the Firm is committed to having a Plan in place to keep its stakeholders informed during times of business interruptions.

While Marathon Capital’s Plan cannot eliminate all risk of service interruption, we periodically assess and update our plan to mitigate all reasonable risk. As with any matter of this importance, we are continually reviewing and evaluating our Plan to implement improvements, and as such, the Plan and this notice are subject to modifications. If you have additional questions about Marathon Capital’s Plan, please contact Compliance@marathoncapital.com. Please bear in mind that we will not respond to specific questions about the program that could compromise our security.

This notice in its most current form will be posted on our website, www.marathoncapital.com.

October 2024