_______________________________________________________________________ Firm Description COSTELLO ASSET MANAGEMENT, INC. was founded as a corporation in November, 1996. The firm was approved to conduct business as a registered investment advisor in May, 1999. COSTELLO ASSET MANAGEMENT, INC. provides investment advisory services to individuals, non-profits, trusts, estates and other business entities. Advice is provided through consultation with the client and may include: determination of client’s investment objectives, identification of financial goals and risks, current and expected cash flow needs, education funding and retirement and estate planning. COSTELLO ASSET MANAGEMENT, INC. provides investment advisory services on a fee-only basis. In this capacity the firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products, and is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted when the firm is functioning as an Investment Advisor. COSTELLO ASSET MANAGEMENT, INC. may directly compensate for client referrals. This is typically done by sharing investment management fees paid by the client. See disclosure below regarding client referrals. Investment advice is an integral part of advisory services. COSTELLO ASSET MANAGEMENT, INC. may counsel clients regarding spending habits, college planning, retirement planning, tax planning and estate planning. It is the client’s responsibility to follow the advice. Investment advice is provided with initial and ongoing consultation regarding client investment needs and wants with COSTELLO ASSET MANAGEMENT, INC. making the financial decision on investment selection. COSTELLO ASSET MANAGEMENT, INC. does not act as a custodian of client assets. COSTELLO ASSET MANAGEMENT, INC. places trades for clients under limited power of attorney. The initial client meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which investment advisory services may be beneficial to the client. _______________________________________________________________________ Principal Owner Robert F. Costello, Jr. is a 100% stockholder of COSTELLO ASSET MANAGEMENT, INC. _______________________________________________________________________ Advisory Services COSTELLO ASSET MANAGEMENT, INC. provides investment advisory services, also known as asset management services. We may manage investment advisory accounts not involving investment supervisory services; furnish investment advice through consultations; and by mail or email issue quarterly newsletters that provide opinions which clients may use to evaluate securities. On an occasional basis, COSTELLO ASSET MANAGEMENT, INC. furnishes advice to clients on matters not involving securities such as on overall spending, taxation and estate planning. As of February 21, 2024, COSTELLO ASSET MANAGEMENT, INC. actively manages $212,886,502 in investments for approximately 690 client accounts. Approximately $212,886,502 is managed on a discretionary basis, and $00.00 is managed on a non-discretionary basis. Tailored Relationships The goal and objectives for each client are documented in our Client Investment Policy Questionnaire. Clients are asked many probing questions to determine investment objectives, asset allocation goals and risk and return expectations. Clients may impose restrictions on investing in certain securities. All clients are asked to complete a questionnaire when opening a new account. _____________________________________________________________________________________ Type of Agreement The following agreement defines the typical client relationship. ____________________________________________________________________________________ Investment Advisory Agreement COSTELLO ASSET MANAGEMENT, INC.’s clients choose us to manage their assets in order to obtain ongoing in-depth account advice and management. All aspects of the client’s financial affairs are reviewed, including those of their dependent children. Realistic and measurable goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. It is the client’s responsibility to be truthful regarding all information discussed with COSTELLO ASSET MANAGEMENT, INC. The fee for Investment Advisory Services is provided to the client in writing prior to the start of the relationship. All clients must sign the investment advisory fee authorization agreement. Advisor shall provide the services under this Agreement for an advisory fee based upon a percentage of assets under its management. Client and Advisor have agreed to a fixed annual percentage rate of ______%. The advisory fee is payable quarterly, in arrears, based on the value of the Account(s) at the end of the immediately

preceding calendar quarter. The value of Account for the purpose of computing the advisory fee shall be the sum of the cash plus the fair market value of the securities in the Account on the date of determination. If the Agreement begins on the day that is not the first day of a calendar quarter, the fee for the quarter will be appropriately prorated. If the Agreement terminates before the last day of a calendar quarter, the fee for such quarter will be prorated for the period in such a quarter after the date of termination. Costello Asset Management, Inc. may not be compensated on a basis of a share of capital gains upon or capital appreciation on the funds or any portion of the funds of a Client. ____________________________________________________________________________________ Asset Management Assets are invested primarily through discount brokers. Fund companies charge each fund shareholder an investment fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of mutual funds. Stocks and bonds may be purchased or sold through client brokerage accounts of their choosing. The brokerage firm may charge a transaction fee to the client for investment trades. Suitable investments may include: equity (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, U.S. government securities, options contracts, ETF’s, stock or bond mutual funds, limited partnerships, and initial public offerings (IPOs) may be purchased for client accounts through COSTELLO ASSET MANAGEMENT, INC. Although the Investment Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of services to the client is at the client’s discretion. The client may terminate the investment advisory agreement by written notice to the other party. At termination, fees will be billed on a pro-rata basis by COSTELLO ASSET MANAGEMENT, INC. for the portion of the calendar quarter that the client account was managed. The value of the managed account at the completion of the service agreement is used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination and any asset flows in and out of the account during the quarter. The client is responsible to pay the investment advisory firm the fee for services provided during the terminating quarter on a pro rata basis and the quarter prior to termination. _____________________________________________________________________________________ Retirement Plan Rollovers – No Obligation/Conflict of Interest A Client or prospective client leaving an employer has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If COSTELLO ASSET MANAGEMENT recommends that a client roll over their retirement plan assets into an account it manages, such a recommendation creates a conflict of interest if COSTELLO ASSET MANAGEMENT will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Registrant. _____________________________________________________________________________________ Portfolio Activity COSTELLO ASSET MANAGEMENT has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, COSTELLO ASSET MANAGEMENT will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when COSTELLO ASSET MANAGEMENT determines changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, there can be no assurance that investment decisions made by COSTELLO ASSET MANAGEMENT will be profitable or equal any specific performance levels. _____________________________________________________________________________________ Cash Positions COSTELLO ASSET MANAGEMENT may maintain cash and cash equivalent positions (such as money market funds) for defensive and liquidity purposes. Unless otherwise agreed in writing, all cash and cash equivalent positions will be included as part of assets under management for purposes of calculating COSTELLO ASSET MANAGEMENT’s investment advisory fee.