Item 5 – Account Requirements and Types of Clients .......................................................................... 20 Item 6 – Portfolio Manager Selection and Evaluation ........................................................................... 20 Item 7 – Client Information Provided to Portfolio Managers ............................................................... 21 Item 8 – Client Contact with Portfolio Managers .................................................................................... 21 Item 9 – Additional Information ................................................................................................................... 21 Form ADV Part 2B – Brochure Supplement .......................................................................................................... 23 James E. Bradley III, CFP®, CFA, CAIA® ............................................................................................................................ 23 P a g e | 4 Form ADV Part 2B – Brochure Supplement .......................................................................................................... 26 Craig A. Joncas, CFP® ........................................................................................................................................................ 26 Form ADV Part 2B – Brochure Supplement .......................................................................................................... 29 Samuel David Chaplin, CFA................................................................................................................................................ 29 Form ADV Part 2B – Brochure Supplement ......................................................................................................... 31 Tyler J. Hafford, CFP® ......................................................................................................................................................... 31 Form ADV Part 2B – Brochure Supplement ............................................................................................................ 3 Elizabeth S. McKay, CFP® .................................................................................................................................................... 3 Form ADV Part 2B – Brochure Supplement ............................................................................................................ 6 Jessica Dolmage, C F P® ...................................................................................................................................................... 6 Form ADV Part 2B – Brochure Supplement ............................................................................................................ 9 Karen Elise Kilbride, C F P®, C P A ....................................................................................................................................... 9 Form ADV Part 2B – Brochure Supplement .......................................................................................................... 12 Colby Jodan Mank .............................................................................................................................................................. 12 Form ADV Part 2B – Brochure Supplement .......................................................................................................... 14 Rebecca Marie Angelica Schuman ..................................................................................................................................... 14 Privacy Policy .......................................................................................................................................................... 16 P a g e | 5 A. Firm Information Penobscot Wealth Management d/b/a Penobscot Financial Advisors (“Penobscot Financial Advisors” or the “Advisor”) is a registered investment adviser with the SEC, which is organized as a Corporation under the laws of the State of Maine. The firm was originally founded in 2000 as Bradley & Johndrow and has been known as Penobscot Financial Advisors since June 2011. Penobscot Financial Advisors is owned and operated by James E. Bradley III (Chief Investment Officer and Craig A. Joncas (Principal and Chief Executive Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Penobscot Financial Advisors. The Advisor acts as a fiduciary to Clients, as defined under applicable laws and regulations. As such, each recommendation made as part of the advisory services are based on the belief that the recommendation is in the Client's best interest. The fiduciary commitment to each Client is further described in the Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. B. Advisory Services Offered Penobscot Financial Advisors offers advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, and retirement plans in the State of Maine and other states (each referred to as a “Client”). Wealth Management Services Penobscot Financial Advisors provides Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with discretionary management of investment portfolios. These services are described below. Financial Planning Services Penobscot Financial Advisors will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial condition, depending on their goals, objectives and financial situation. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting encompasses one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to, the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Penobscot Financial Advisors may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. Planning as part of annual retainer or comprehensive wealth management is an ongoing process where the Advisor is available for consultation throughout the year. Financial planning and consulting recommendations may pose

a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for asset management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any recommendations made by the Advisor, the Client is under no obligation to affect the transaction through the Advisor. In addition, Penobscot Financial Advisors also offers ongoing financial planning services on an annual retainer. The ongoing financial planning services are customized to the Client’s needs and covers a range of financial planning and consulting services depending on the Client’s goals, objectives and financial situation. P a g e | 6 UMS Financial Planning Services Penobscot Financial Advisors will typically provide a limited financial plan to University of Maine employees, pursuant to a written financial planning agreement. This plan is a limited scope, covering primarily retirement planning, investment planning and advice regarding their employee benefits. Generally, such financial planning services involve preparing a limited financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting encompasses one or more areas of need, limited to retirement planning, investment planning and advice regarding their employee benefits. A financial plan developed for, or financial consultation rendered to, the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, or changing employee benefit elections. Penobscot Financial Advisors may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. The planning services will be considered render in full upon delivery of the financial plan. For ongoing Financial Planning Services beyond the delivery of the limited financial plan, the client must enter into a Financial Planning Agreement at the renewal rate or a Wealth Management Agreement. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for asset management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any recommendations made by the Advisor, the Client is under no obligation to affect the transaction through the Advisor. In addition, Penobscot Financial Advisors also offers ongoing financial planning services on an annual retainer. The ongoing financial planning services are customized to the Client’s needs and covers a range of financial planning and consulting services depending on the Client’s goals, objectives and financial situation. Asset Management Services Penobscot Financial Advisors provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary asset management and related advisory services. Penobscot Financial Advisors works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Penobscot Financial Advisors will then construct a portfolio, consisting of diversified mutual funds closed end funds, hedge funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction. Penobscot Financial Advisors’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Penobscot Financial Advisors will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Penobscot Financial Advisors evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Penobscot Financial Advisors may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Penobscot Financial Advisors may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Penobscot Financial Advisors may recommend selling positions for reasons that include, but are not limited to: harvesting capital gains or losses, reducing business or sector risk exposure to a specific security or class of securities, resolving overvaluation or overweighting of the position[s] in the portfolio, adjusting to a change in risk tolerance of Client, generating cash to meet Client needs, or mitigating any risk deemed P a g e | 7 unacceptable for the Client’s risk tolerance. At no time will Penobscot Financial Advisors accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated account[s], pursuant to the Client’s agreement. Please see Item 12 – Brokerage Practices and Item 15 – Custody which outlines instances of incidental custody due to deduction of management fees and Standing Letters of Authorization to assist Client’s with cashiering needs upon their instruction. Retirement Plan Advisory Services Penobscot Financial Advisors provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Employee Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Asset Management
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services Certain of these services are provided by Penobscot Financial Advisors serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Penobscot Financial Advisors’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Penobscot Financial Advisors to provide advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Penobscot Financial Advisors, in connection with the Client, may develop a strategy designed to meet the Client’s investment goals and objectives.
• Asset Allocation – Penobscot Financial Advisors will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction – Penobscot Financial Advisors will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Asset Management and Supervision – Penobscot Financial Advisors will provide asset management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Penobscot Financial Advisors includes securities transaction fees together with its wealth management and investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its asset management services for its Clients. The Advisor sponsors the Penobscot Financial Advisors Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2023, Penobscot Financial Advisors manages approximately $334,340,316 in discretionary assets and $70,613,146 in non-discretionary assets. Clients may request more current information at any time by contacting the Advisor. P a g e | 8