COMPANY HISTORY & PRINCIPALS ACIMA Private Wealth LLC (“ACIMA” or the “Firm” “we” or “us”) is a limited liability company formed in the State of Virginia. ACIMA was founded in May 2015 as a fee-only investment advisory firm with the intent to provide exceptional service to high- net-worth individuals, families, trusts, charitable foundations and institutions. As of May, 2017, the Firm is registered as an investment adviser with the Securities and Exchange Commission (“SEC”). Gary M. Gore is the Founder and Managing Member of ACIMA. He serves as President and Chief Executive Officer and is the principal owner of the Firm. ACIMA’s purpose is to implement integrated wealth management solutions that meet the financial needs and reflect the personal values of our clients. The Firm’s focus will be to assist our clients in identifying and achieving their personal and financial objectives in collaboration with their professional advisers. Clients will work with a personal adviser who has skills and experience serving high-net-worth clients, families and institutions. Clients will work with advisers who have built relationships based on trust with clients they know and understand, and who are flexible, unbiased and conflict-free decision makers. Prior to founding ACIMA, Mr. Gore spent 25 years in the financial services industry. During that time, he held several key positions serving corporations, private businesses, families and individuals. Most recently, he served as the Regional Executive and Managing Director of U.S. Trust, catering to the holistic wealth management needs of high-net-worth and ultra-high-net- worth individuals, families and institutions, with responsibility for $15 billion in assets under management. Concurrently, he served as the Virginia State President for Bank of America, the parent company to U.S. Trust, as well as the Richmond Market President. INVESTMENT ADVISORY SERVICES ACIMA follows an investment philosophy that is uniquely disciplined, customized, tax/fee-sensitive and takes an open architecture approach that may incorporate active and passive strategies. We provide investment advisory services to individuals, high-net-worth individuals, trusts, endowments, small businesses, family offices and other institutional clients through separately managed accounts. Continuous advice is provided to a client regarding the investment of client funds and is based on the individual needs of the client. Through discussions with our clients, we come to understand our clients’ objectives, goals and particular circumstances. We then develop a client’s personal investment policy statement, recommending and managing a portfolio based upon that policy statement. During our data gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and may include advice regarding the following types of securities: exchange-listed securities, securities traded over- the-counter, foreign issuers, corporate debt securities (other than commercial paper), commodities, municipal securities, mutual fund (institutional shares), United States governmental securities, options, alternative investments and/or annuities. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. FINANCIAL PLANNING ACIMA provides financial planning services to its clientele. Financial planning is an evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients utilizing this service receive a written report providing the client with a detailed financial plan designed to assist the client in achieving stated financial goals and objectives. Version: ACIMA-ADV2A-Mar.28.2024 Page 5 of 17 We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Co-Planning Services. ACIMA may engage an unaffiliated registered investment adviser to assist with the financial planning process. In such event, the unaffiliated adviser shall be required to comply with regulatory client confidentiality and privacy requirements. In the event that the unaffiliated adviser provides services directly to any of ACIMA’s clients, the client shall be provided with a copy of the unaffiliated adviser’s written Disclosure Brochure as set forth on Part 2A of Form ADV, the corresponding Part 2B for adviser’s representative; and, to the extent applicable, planner’s Form CRS (Client Relationship Summary). FAMILY WEALTH SERVICES ACIMA provides an integrated wealth management service which includes multi-generational planning, financial education, strategies for funding trusts, advice on charitable giving, personalized reporting, concierge services and coordination with a client’s other business professionals to assist in risk management strategies. Our clients are often involved in complex financial situations across multiple disciplines that require comprehensive, integrated, and objective advice. ACIMA advisers will apply their deep understanding of these unique and complex requirements to develop the most suitable solution. The process begins with an extensive review of the client’s goals, objectives, dreams and aspirations to develop a strategic plan. The plan includes details from current needs to goals for future generations. We assist in funding trusts, philanthropic planning, risk management analysis, household administration and coordinating with other service providers in regards to estate planning, asset titling and protection. ACIMA PRIVATE WEALTH WRAP FEE PROGRAM ACIMA serves as a program sponsor and portfolio manager for its own wrap fee program, the ACIMA Private Wealth Program (the “Program”). If a client participates in the Program, they will pay a single fee which includes financial planning, investment management, portfolio monitoring and financial plan management services as well as custodial and administrative costs incurred within their account(s). An appropriate wrap fee program brochure has been created and will be presented to the client by ACIMA prior to investing in the Program. The Firm’s “Wrap Fee Program Brochure” is available upon request at any time by calling the Chief Compliance Officer at (804) 422-8450. SELECTION OF THIRD PARTY ADVISORS ACIMA may recommend the investment strategies of third party advisers (“TPAs”) to its clients. At this time, ACIMA has no arrangements in place with a TPA. In the future, if a TPA is selected to manage a portion of a client’s assets, the client will execute a separate investment management agreement with the TPA. The TPA selected may offer its services through its own wrap fee program. If a wrap fee program is selected for a portion of a client’s assets in the future, the Form ADV Part 2A and the wrap fee brochure for the TPA’s program will be presented to the client. The TPA’s Wrap Fee Program Brochure will describe the investment strategy as well as the fees and services to be performed by the TPA. ACIMA will not receive a referral fee or participate in any revenue sharing with the

TPA. ASSETS UNDER MANAGEMENT As of February 29, 2024 ACIMA manages $339,856,143 on a discretionary basis and no assets on a non-discretionary basis. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent specifically requested, ACIMA will generally provide planning and consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. ACIMA, in its sole discretion, based upon various Version: ACIMA-ADV2A-Mar.28.2024 Page 6 of 17 factors such as complexity and assets under management, may determine to provide such services inclusive of its advisory fee set forth at Item 5 below (exceptions will occur based upon assets under management, advanced planning needs, special projects, etc. for which ACIMA may charge a mutually agreeable additional fee and/or require a stand- alone financial planning engagement). Please Note: ACIMA does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, ACIMA does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from ACIMA and/or its representatives. Please Also Note: If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not ACIMA, shall be responsible for the quality and competency of the services provided. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically 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 ACIMA recommends that a client roll over their retirement plan assets into an account to be managed by ACIMA, such a recommendation creates a conflict of interest if ACIMA will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, ACIMA serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by ACIMA. ACIMA’s Chief Compliance Officer, Gary Gore, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Wrap Program-Conflict of Interest. With limited exception, ACIMA provides services on a wrap fee basis as a wrap program sponsor. Under ACIMA’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in ACIMA’s Wrap Fee Program Brochure. Conflict of Interest. Because wrap program transaction fees and/or commissions are being paid by ACIMA to the account custodian/broker-dealer, ACIMA could have an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client's account. See separate Wrap Fee Program Brochure. ACIMA’s Chief Compliance Officer, Gary Gore, remains available to address any questions that a client or prospective client may have regarding a wrap fee arrangement and the corresponding conflict of interest. Custodian Charges-Additional Fees: As discussed below at Item 12 below, when requested to recommend a broker- dealer/custodian for client accounts, ACIMA generally recommends that Schwab serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge transaction fees for effecting securities transactions. In addition to ACIMA’s investment advisory fee referenced in Item 5 below, the client (unless it engages ACIMA on a wrap fee basis per the above) will also incur transaction fees to purchase securities for the client’s account (i.e., mutual funds exchange traded funds, individual equity and fixed income securities, etc.) ANY QUESTIONS: ACIMA’s Chief Compliance Officer, Gary Gore, remains available to address any questions that a client or prospective client may have regarding the above. Please Note-Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by ACIMA independent of engaging ACIMA as an investment advisor. However, if a prospective client determines to do so, he/she will not receive ACIMA’s initial and ongoing investment advisory services. Please Also Note: In addition to ACIMA’s investment advisory fee described below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). ANY QUESTIONS: ACIMA’s Chief Compliance Officer, Gary Gore, remains available to address any questions that a client or prospective client may have regarding the above. Tradeaway/Prime Broker Fees. If, in the reasonable determination of ACIMA that it would be beneficial for the client, individual fixed income transactions may be effected through broker-dealers other than the account custodian, in which event, the client generally will incur both the fee (commission, mark-up/mark-down) charged by the Version: ACIMA-ADV2A-Mar.28.2024 Page 7 of 17 executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account custodian (i.e., Schwab). ANY QUESTIONS: Our Chief Compliance Officer, Gary Gore, remains available to address any questions that a client or prospective client may have regarding tradeaway arrangements. Portfolio Activity. ACIMA has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, ACIMA 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, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when ACIMA determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by ACIMA will be profitable or equal any specific performance level(s). Client Obligations. In performing our services, ACIMA shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify ACIMA if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by ACIMA) will be profitable or equal any specific performance level(s).