A. Description of the Advisory Firm Flagship Private Wealth (hereinafter “FPW”) is a Limited Liability Company organized in the State of Massachusetts. The firm was formed in June 2012, and the principal owners are Ronald Giunta, Elizabeth Johnson, and Karl Warner. B. Types of Advisory Services Portfolio Management Services FPW offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. FPW documents the client’s current situation including, but not limited to, income, tax levels, and risk tolerance levels. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring FPW evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. FPW will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. FPW seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of FPW’s economic, investment or other financial interests. To meet its fiduciary obligations, FPW attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, FPW’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is FPW’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Selection of Other Advisers FPW may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, FPW will always ensure those other advisers are properly licensed or registered as an investment adviser. FPW conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. FPW then makes investments with a third-party investment adviser by referring the client to the third-party adviser. FPW will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt /credit planning. Services

Not Limited to Specific Types of Investments FPW does not limit the types of investments that we recommend. Written Acknowledgement of Fiduciary Status When FPW provides investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement account. The way FPW makes money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services;
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions FPW offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FPW from properly servicing the client account, or if the restrictions would require FPW to deviate from its standard suite of services, FPW reserves the right to end the relationship. D. Wrap Fee Programs FPW acts as sponsor for a wrap fee program (Flagship Private Wealth Wrap Fee Program), which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Clients utilizing FPW’s wrap fee portfolio management should see the separate Wrap Fee Program Brochure in Appendix 1. FPW manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. FPW receives the advisory fee set forth in Item 5 below as a management fee under the wrap fee program. Please also see Item 5 and Item 12 of this brochure. E. Assets Under Management FPW has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 270,186,499.00 $ 0 January 1, 2023