Keeney Financial Group Inc. (“KFG”) has been in business since October, 2015. John P. Keeney is the firm’s only principal owner. Mr. Keeney has worked in the field of financial management since 1987. KFG provides personalized financial planning and investment management services to individuals, families, trusts, charitable organizations and foundations, pensions and corporations. KFG’s mission is to provide clients with the comfort that comes from having the clarity to focus on what really matters, freeing clients to face their future with confidence. KFG serves as an independent and unbiased advisor to our clients, characterized by a high level of accountability across our organization. We constantly strive to earn and keep your trust through transparency in all that we do. As we work together, we want you to know that we are exactly who we claim to be. We truly believe that we earn our clients’ business every day. We strive to anticipate, rather than react. Each client who engages KFG for asset management services are strongly encouraged to complete a financial plan, whether it is done by KFG or another advisor. Clients without financial plans may still work with KFG, but the asset management transition process may not be as efficient as it would have been with a financial plan in place. In the absence of a financial plan, client’s investment objectives are determined a number of factors, including risk tolerance, liquidity needs, current investments, time horizon, income needs, tax consideration and purpose of the funds. The planning process results in an assessment of that particular client’s needed rate of return to provide them with the means to meet their financial goals or life goals. From this potential rate of return, KFG works to create a portfolio KFG feels is most likely to meet that potential rate of return over the timeline the client requires, without adding undue risk. When we perform asset management services, we will do so on a discretionary basis. This means that while we will continue an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, but we will not seek specific approval of changes to client accounts. Clients can always make deposits or withdrawals in their accounts at any time. Clients should be aware that if KFG is managing your assets, you may not be able to place restrictions on the types of investments in an account or portfolio. Because we take discretion when managing accounts, clients engaging us will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and KFG. In very limited circumstances, we may provide investment management services on a non-discretionary basis, which means we will manage the clients’ accounts as we do for our discretionary clients, except we will consult with the client prior to implementing any investment recommendation. Clients should be aware that some recommendations may

be time-sensitive, in which case recommendations not implemented because we are unable to reach a non-discretionary client may not be made on a timely basis and therefore client’s account may not perform as well as it would have had KFG been able to reach the client for a consultation on the recommendation. Financial Planning KFG believes that thoughtful financial planning can be an effective tool for protecting and accumulating wealth. It can also assist in the planning for special needs for clients and their heirs. KFG will provide planning services to any client, whether they wish to become an asset management client or not. If you request, KFG may recommend the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from KFG. If you engage any professional recommended by KFG, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Conflict of Interest – IRA Rollover Recommendations When recommending that a client rollover his or her account from current retirement plan to an IRA, KFG and its investment adviser representatives have a conflict of interest. KFG and its representatives can earn investment advisory fees by recommending that a client rollover his or her account at the retirement plan to an IRA; however, KFG and its investment adviser representatives will not earn any investment advisory fee if client does not rollover the funds in the retirement plan (unless a client retained the firm to provide advice about the client’s retirement plan account or the retirement plan has retained the firm to provide advice at the plan level). Thus, KFG and its investment adviser representatives have an economic incentive to recommend a rollover of the retirement plan account, which is a conflict of interest. KFG has taken steps to manage this conflict of interest arising from rolling over funds from an ERISA covered retirement plan to an IRA. KFG and its investment adviser representatives will (i) provide investment advice to ERISA covered retirement plan participant regarding a rollover of funds from the ERISA covered retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in the firm receiving unreasonable compensation related to the rollover of funds from the ERISA covered retirement plan to an IRA, and (iii) fully disclose compensation received by KFG and its supervised persons and any material conflicts of interest related to KFG recommending the rollover of funds from the ERISA covered retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. Assets under Management As of February 14, 2023, KFG has approximately $385,599,261 in assets under management, in 1,179 accounts. Of these accounts, all assets are managed on a discretionary basis.