A. Description of the Advisory Firm SHP Wealth Management, LLC (hereinafter “SWML”) is a Limited Liability Company organized in the State of Massachusetts. The firm was formed in December 2014, and the owner is SHP Holding, LLC. SHP Holding, LLC is owned by Keith Ellis & Associates, LLC, Gregoire & Associates, LLC and Helicon MTN Group, Inc. Helicon MTN Group Inc. is owned by Matthew C. Peck, CFP®, CIMA®, Gregoire & Associates, LLC is owned by Derek Louis Gregoire and Keith Ellis & Associates, LLC is owned by Keith W Ellis Jr. B. Types of Advisory Services Portfolio Management Services SWML offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWML creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. 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 SWML evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWML will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. SWML seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWML’s economic, investment or other financial interests. To meet its fiduciary obligations, SWML attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWML’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 SWML’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services SWML offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: o identifying investment objectives and restrictions o providing guidance on various assets classes and investment options o recommending money managers to manage plan assets in ways designed to achieve

objectives o monitoring performance of money managers and investment options and making recommendations for changes o recommending other service providers, such as custodians, administrators and broker-dealers o creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Subadviser Services SWML may also act as a subadviser to advisers unaffiliated with SWML. These third party advisers would outsource portfolio management services to SWML. This relationship will be memorialized in each contract between SWML and the third party advisor. This would include model portfolio construction to outside RIA’s that wish to gain access to our portfolio construction and research. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; health insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Educational seminars and workshops. SWML provides periodic educational seminars and workshops to clients. Services Limited to Specific Types of Investments SWML generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. SWML may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SWML will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by SWML on behalf of the client. SWML may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. 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 SWML from properly servicing the client account, or if the restrictions would require SWML to deviate from its standard suite of services, SWML reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. SWML does not participate in any wrap fee programs. E. Assets Under Management SWML has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $875,411,914 $30,275,290 December 2022