Firm Description Apogee Investment Management (AIM or the Firm) is an Independent Registered Investment Adviser (RIA) providing advice to individuals, charitable organizations, foundations, endowments, 401k plans and profit-sharing plans. The company has been in existence since January 1, 2015 and has two offices: 64 S. Ramona Beach Road in Pulaski, NY 13142 and 28 Sunridge Drive in Coraopolis, PA 15108. Principal Owner AIM is 100% owned by Kevin VandenBerg. Types of Advisory Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to a client’s needs. As used in this brochure, the words "we", "our" and "us" refer to Apogee Investment Management (AIM) and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Investment Management Services AIM provides continuous advice to clients regarding investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s circumstances are established, AIM creates and manages an investment portfolio. AIM will manage advisory accounts on a discretionary and non- discretionary basis, but almost exclusively on a discretionary basis. Account supervision is guided by the stated objectives of the client. If you participate in our discretionary asset management services, we require you to grant our firm discretionary authority to manage their accounts. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Our fee is billed and payable quarterly, in advance, based on the market value of your account on the beginning of the quarter in which it is billed. The asset-based fee for the initial quarter shall be calculated on a pro rata basis (only in initial quarter) commencing on the day the portfolio assets are initially designated to us for Investment Supervisory Services under this Agreement. No portion of the asset-based fee is calculated on the performance of the Account. We may allow accounts of members of the same household to be aggregated for purposes of meeting our minimum account size or fee. We may allow 5 APOGEE INVESTMENT MANAGEMENT such aggregation, for example, where we service accounts on behalf of minor children of current clients, individual and joint accounts for a spouse, and other types of related accounts. We will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only after you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. Financial Planning AIM also provides financial planning. Clients using financial planning services may or may not contract with AIM for Asset Management Services. We provide broad based, modular and consultative financial planning services for a fee. Financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. When providing a financial plan, we consider issues such as portfolio diversification, estate planning, retirement planning, disability planning, risk management, general asset management, cash flow, income tax planning and insurance planning. The process typically begins with a complimentary introduction meeting during which the various services we provide are explained. If you decide to engage us for financial planning services, we will collect pertinent information about your personal and financial circumstances and objectives. As required, we will conduct follow-up interviews for the purpose of reviewing and/or collecting additional financial data. Once such information has been reviewed and analyzed, a written financial plan designed to achieve your stated financial goals and objectives may be produced and presented to you. The primary objective of this process is to allow us to assist you in developing a strategy for the successful management of income, assets and liabilities in meeting your financial goals and objectives. In some circumstances, clients may only require advice on a single aspect of the management of their financial resources. For these clients, we offer financial plans in a limited modular format and/or general consulting services that address only those specific areas of interest or concern. Financial plans are based on your financial situation at the time we present the plan, and on the financial information you provide our firm. In providing the contracted services, we are not required to verify any information we receive from you or from your other professionals (e.g. attorney, accountant, etc.) and we are expressly authorized to rely on the information you provide. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. For broad-based financial planning services, we

charge a fixed fee of $2,200. For limited modular plans, we charge a negotiable reduced amount depending on the scope and complexity of the plan. We may require 50% of the fee to be paid in advance with the 6 APOGEE INVESTMENT MANAGEMENT remainder due upon presentation of the plan. Our fees are negotiable depending on the nature, complexity, and time involved in providing the requested services. In certain circumstance, the fees may exceed the initial fee quoted, in which case, we will obtain your approval before performing additional services. We charge a negotiable fixed fee of $850 for updates to a financial plan. For hourly consulting services, our negotiable fees range between $150 and $300 and is generally due upon completion of the consultation. At our discretion, we may waive and/or reduce financial planning fees if clients retain us for asset management services. In the event clients implement a plan by purchasing insurance products through associated persons of our firm, in their capacity as insurance agents, we may offset our financial planning fees against the insurance commission earned. Either party, upon written notice to the other, may terminate the financial planning agreement. In the event of termination, you will be charged for the portion of work we have performed through the date of termination and, if applicable, you will receive a pro- rated refund for any unearned fees which you have paid in advance. The agreement may not be assigned without the consent of the client. Financial planning may address any, or all, of the following areas of concern:
• Personal: Family records, budgeting, personal liability, estate information and financial goals.
• Education: Education IRAs, financial aid, state savings plans, grants and general assistance in preparing to meet dependents continuing educational needs through development of an education plan.
• Tax Cash Flow: Income tax and spending analysis and planning for past, current and future years. AIM will illustrate the impact of various investments on a client’s current income tax and future tax liability.
• Death and Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis.
• Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.
• Investments: Analysis of investment alternatives and their effect on a client’s portfolio.
• Estate: Living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law.
• Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long term care, liability, home and automobile. Financial planning clients may receive a written report, providing a detailed financial plan designed to achieve their stated financial goals and objectives. AIM gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes toward risk. Related documents including a questionnaire completed by the client, supplied by the client are carefully reviewed, and a written report is prepared. If a client chooses to implement the recommendations contained in the plan, AIM suggests the client work 7 APOGEE INVESTMENT MANAGEMENT closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations with AIM is entirely at the client’s discretion. Financial planning recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Tax Preparation Apogee Investment Management may provide (outsourced) tax preparation services upon client request. In doing so, AIM has negotiated a discounted fee for clients, but does not receive any remuneration from the accountant. Fees for tax prep are deducted from client accounts and paid directly to the accountant at the discounted rate. This discounted rate is communicated to clients prior to any tax work being done. Types of Investments AIM will create a portfolio consisting of one or all of the following: individual equities, bonds, ETFs, ETN’s, no-load or load-waived mutual funds, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual fund shares), U.S. government securities, options contracts, futures contracts, interests in partnerships, or other investments. When appropriate to the needs of the client, AIM may recommend the use of option writing. Because this investment strategy involves certain additional degrees of risk, it will only be recommended when consistent with the client’s stated tolerance for risk. You may request that we refrain from investing in particular securities or certain types of securities, but you must provide these restrictions to our firm in writing. Wrap Fee Programs AIM does not participate in a Wrap Fee Program. Client Assets As of December 31, 2023, AIM has $108,150,666.98 in discretionary assets under management and 115 clients. AIM has $0 in non-discretionary assets and 0 clients. However, for audit purposes, that number is $4,812,520.58 and 12 clients. Current census on next page 8 APOGEE INVESTMENT MANAGEMENT Current client census is as follows (115): California 2 Colorado 1 Connecticut 1 Florida 8 Georgia 2 Massachusetts 3 Michigan 2 New York 79 North Carolina 1 Ohio 1 Oklahoma 1 Pennsylvania 5 South Carolina 1 Tennessee 2 Texas 3 Vermont 1 Virginia 1 Washington 1 TOTAL 115 9 APOGEE INVESTMENT MANAGEMENT