A. DESCRIPTION OF THE ADVISORY FIRM. Haverdink Financial Management, LLC (“Haverdink Financial Management” or “Adviser”) has been in the investment advisory business since May 2004. The Adviser is registered with and regulated by the United States Securities and Exchange Commission. Haverdink Financial Management is 100% owned by The Kevin and Laura Haverdink Revocable Trust. Kevin Haverdink is trustee and the Adviser’s President and Chief Compliance Officer. Mr. Haverdink is registered as an Adviser Representative of the Adviser. Laura Haverdink is trustee and holds the titles of Vice-President, Secretary and Treasurer. Ms. Haverdink provides professional administration services and does not engage in providing financial or investment advisory services. B. TYPES OF ADVISORY SERVICES Haverdink Financial Management, LLC, (“Haverdink Financial Management” or the “Adviser”), is a fee only Registered Investment Adviser. The term “fee only” means that Haverdink Financial Management and its Adviser Representatives do not accept commissions in connection with securities or insurance recommendations. Haverdink Financial Management is only compensated for advisory services via a percentage of assets under management; hourly fees or project-based fees depending upon the services requested and scope of the engagement. The Adviser is a fiduciary to each of its clients. “Adviser Representatives” are those persons authorized by the firm to deliver financial and investment advisory services. Adviser Representatives of Haverdink Financial Management are not registered representatives of a broker/dealer and the Representatives are not insurance agents. The Adviser is not a broker/dealer or custodial firm. All transactions in securities will be executed by an unaffiliated custodial firm of clients’ choosing. Haverdink Financial Management may offer a complimentary general consultation to discuss services available, to give a prospective client time to review services desired, and to determine the possibility of a potential Client-Adviser relationship. Services begin only after the client and Adviser formalize the relationship with a properly executed Client Agreement. After the formal engagement and depending upon the scope of the engagement, the Adviser and client will share in a data gathering and discovery process in an effort to determine the client’s needs, goals, intentions, time horizons, risk tolerance and investment objectives, based upon information provided by the client and the nature of services requested. The client and Adviser may complete a risk assessment, investment policy statement or similar document, depending upon the nature of services to be provided. Haverdink Financial Management offers Investment Management, Financial Planning, and General Consultation Services. On occasion, the Adviser may also offer General Education Seminars or Workshops. 1. Investment Management Services are ongoing in nature, focus solely on portfolio management, and do not include financial planning services or consultation services outside the scope of the managed investments. 2. Financial Planning Services are hourly or project-based services and generally terminate upon the delivery of services unless otherwise agreed in writing. 3. Consultation Services are hourly or project-based services and generally terminate upon the delivery of services unless otherwise agreed upon in writing. 4. General Education Seminars and Workshops are individual general education opportunities in connection with investment management and/or financial planning topics. The content is general in nature and does not constitute individualized services. Participants are welcome but are never obligated to contact the Haverdink Financial Management for advisory services. 1. Investment Management Services involve ongoing and continuous portfolio management. Haverdink Financial Management focuses on providing individualized services that are tailored to meet the stated needs and objectives of the client. In the delivery of initial and ongoing services and based upon the client’s level of participation, the Adviser will normally include a comprehensive review of the overall aspects of a client’s current financial situation and consider both long and short-term objectives and goals, or as directed by the client. Clients engaging in Investment Management Services must play an active role. The Adviser requires the client to participate in the financial and investment review; the development of an investment policy or similar document, if applicable; the development of the investment plan to be followed; as well as participation in reviews and the ongoing advice and recommendations. Depending on the nature of the services to be provided, Haverdink Financial Management generally develops and utilizes an asset allocation model that is consistent with the client’s desired rate of return, time horizon and risk tolerance. Haverdink Financial Management can design and implement a portfolio or assist with the implementation. Where a portfolio has been designed by the client or another party, Haverdink Financial Management will provide recommendations for re-design, adjustments or re-balancing. Once the portfolio has been implemented or transferred for services, Haverdink Financial Management can provide continuous monitoring, recommendations and investment advice as outlined in the engagement for services. The ongoing Investment Management Services is based upon a targeted asset allocation agreed upon between Haverdink Financial Management and the client. In providing ongoing Investment Management Services, the Adviser will manage investor funds in accordance with an investment plan as selected by the client and the Adviser will remain available for ongoing advice and recommendations. The Adviser will monitor the portfolio in accordance with the directives provided. Investment Management Services are continuous in nature and thus are ongoing until terminated by either party. Haverdink Financial Management can tailor services to focus only on certain portfolio components or the Adviser can provide comprehensive portfolio management services, depending upon the client’s wishes and/or the nature of the engagement. The Adviser welcomes the opportunity to provide individualized services. However, where investment management services or information are limited, clients must understand that comprehensive investment needs and or objectives may not be fully considered due to the client’s option not to receive limited services, the lack of information received, and/or client disclosure. Investment Management Services generally begin with an initial data-gathering interview in an effort to determine the client’s stated individual needs, goals, time horizons and risk tolerance. Haverdink Financial Management utilizes the information provided by the client to prepare recommendations for investments, which may include planning for long- range goals (i.e., retirement planning or college funding) or other segments of an investment plan that may be desired. After an analysis and data-gathering process and depending upon the nature of services desired, the Adviser may prepare reviews, analysis, asset allocation recommendations, and may recommend specific investments. Unless otherwise directed by the client, Haverdink Financial Management will generally seek to allocate a client’s assets among various investments, taking into consideration the client’s strategic portfolio framework developed with clients. The Adviser attempts to construct a diversified portfolio of investment recommendations that are within its realm of expertise. In each case, the stated individual needs, goals and desires of clients are taken into consideration. While Haverdink Financial Management will typically recommend investments in mutual funds, index funds, exchange traded funds, individual equities, U.S. government securities, municipal bonds, and other fixed-income securities. The Adviser will generally seek to allocate the client’s assets among various investments, taking into consideration the overall management style and portfolio framework selected by the client. The Adviser attempts to construct a diversified portfolio of investment recommendations that are within its realm of expertise. In each case, the stated individual needs, goals and desires of clients are taken into consideration. Depending on the needs of a client, the Adviser may also evaluate or offer advice on variable life and annuities, but the Adviser does not engage in sales of these types of products. In addition, if requested and based upon information provided by the client, the Adviser can prepare an evaluation of existing portfolio investments and provide recommendations for other investments as deemed appropriate. While the Adviser may offer general advice on partnership investments, including hedge funds, private limited partnerships, etc., the services provided to private investments are limited to consultation regarding the investment opportunity and a review of the offering documents versus the management of partnership investments, unless specifically agreed to in writing. Services and investment recommendations in connection to assets invested in corporate retirement plans are limited to those offered within the plan and via the plan’s contracted service providers. Clients engaging in investment advisory services are expected to play an active role. The Adviser requires the client to participate in the formation of the investment plan, the development of investment advice and recommendations and the ongoing services provided. Clients may call the office during regular business hours to discuss their portfolio or ask questions, but the Adviser recommends that clients initiate a meeting with the Adviser no less than annually. However, clients are obligated to immediately inform the Adviser of any changes in their financial situation to provide the Adviser with the opportunity to review the portfolio to ensure it is still structured to help meet the client’s stated needs and objectives. The services provided by the Adviser are based upon the client’s stated individual needs and objectives. In providing ongoing Investment

Management Services, Haverdink Financial Management will manage investor funds in accordance with an investment policy/strategy or plan as selected by the client and the client’s written directives. The Adviser will remain available for ongoing advice and recommendations throughout the engagement. If services desired go outside the scope of Investment Management Services, the Adviser may be available to provide Consultation and/or Financial Planning Services. In such cases, the Adviser may request a new or amended Client Agreement and additional fees will apply. The Adviser will not engage in additional services without the client’s direction. 2. Financial Planning Services involve hourly or project-based services that may be comprehensive in nature or the services can be tailored to address one or more components of financial planning. Advice may be provided on issues relating to retirement planning, cash flow analysis, sponsored benefit determination, business owner issues, education funding, employee benefit issues, major purchases, and risk management planning. The services requested may include short-term and/or long-term goal planning as directed by the client. The Adviser can tailor services as desired by the client. Financial Planning Services may be general in nature or can be focused on particular areas of interest or components of planning rather than on comprehensive planning, depending upon the client’s needs. The services to be provided and the Adviser’s fee(s) are agreed upon at the time of engagement. As part of the Adviser’s policy toward full disclosure, advisory fees are outlined in advance and in writing before any services are performed. This policy assures that the client’s affairs will be evaluated objectively and in a cost- effective manner. The Adviser reserves the right to increase or decrease the rate or amount of the fee with the consent of the client, based upon individual circumstances, complexities, additional services requested, or a modification in the nature and scope of services. When Financial Planning Services only focus on certain areas of client interests, needs or is otherwise limited, clients must understand that a client’s overall financial and investment needs, liabilities and objectives may not be considered as a result of time and/or service restraints placed on the Adviser’s services. Clients requiring assistance on issues relating to matters outside of financial and investment advisory topics should consult their personal tax adviser, legal counsel, or other professionals for expert opinions. When providing a review or advice on investments within retirement plans, the advice and any recommendations are limited to plan offerings and the service provider(s) selected by the plan providers. Implementation of any advice or recommendations pertaining to securities or non- securities matters, in whole or in part, is entirely at the client’s discretion via the service provider(s) of the client’s choice. Financial Planning Services generally utilize long-term strategies so that continuous monitoring is not required. The advice provided by the Adviser may include recommendations for updates and reviews. Clients are welcome but are never obligated to retain the Adviser for additional or follow-up services. Where additional or new services are desired, Haverdink Financial Management may require an amended or new client agreement. Financial Planning Services will not include any portfolio monitoring, investment reviews or investment management. Investment Management Services may be available via a new client agreement. 3. Haverdink Financial Management is available to provide Consultation Services on an hourly or project basis. Advice may be provided on general issues relating to investments, portfolios, or other issues of interest to clients. The Adviser can tailor services as desired by the client. Consultation Services are not comprehensive in nature in that services only focus on certain areas of client interests, needs or is otherwise limited. Therefore, clients must understand that a client’s overall financial and investment needs and objectives may not be considered as a result of time and/or service restraints placed on the Adviser’s services. The services provided terminate upon delivery unless otherwise agreed in writing. The advice provided by the Adviser may include recommendations for updates and reviews and the client’s responsibility to follow-up and secure additional services under a new or amended agreement. Adviser Representatives may suggest the client work closely with the client’s attorney, accountant, insurance agent, and the client’s custodian. Clients requiring assistance on issues relating to matters outside of investment advisory topics should consult their personal tax Adviser, legal counsel, or other professionals for expert opinions. Implementation of any advice or recommendations pertaining to securities and/or non-securities matters, in whole or in part, is entirely at the client’s discretion via the service provider(s) of the client’s choice. When providing a review or advice on investments within retirement plans, the advice and any recommendations are limited to plan offerings and the service provider(s) selected by the plan providers. The advice provided by the Adviser may include recommendations for updates and reviews and these services can be obtained under a new or amended agreement at the client’s discretion. Consultation Services will not include any portfolio monitoring, reviews, follow-ups, or other services. If additional or new services are desired, clients are welcome to secure these services via a new or amended agreement. Investment Management Services may also be available via a new client agreement. 4. Haverdink Financial Management may also conduct general Educational Workshops and Seminars on topics relating to investment management or financial issues. The presentations will provide general information only. Participants are never obligated but are welcome to seek out individualized services from the Adviser. From time to time, the Adviser may charge a fee for Educational Workshops or Seminars, depending upon the nature of services, complexity of content, materials provided, location, or at the discretion of the Adviser. All fees and the Adviser’s cancellation policy (and refund policy, if applicable) will be clearly noted in the offering document or invitation. C. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS Haverdink Financial Management focuses on providing individualized services. The Adviser can tailor services to focus only on certain portfolio components, depending upon the client’s wishes and/or the nature of the engagement. However, where client services or information are limited, clients must understand that comprehensive financial and/or investment needs and objectives may not be fully considered due to the client’s option to receive limited services, the lack of information received, and/or client disclosure. The Adviser and client will share in a data gathering and discovery process in an effort to determine the client’s stated needs, goals, intentions, time horizons, risk tolerance and investment objectives, based upon information provided by the client and the nature of services requested. The client and Adviser may complete a risk assessment, investment policy statement or similar document, depending upon the nature of services to be provided. Clients may not impose reasonable restrictions in investing in certain securities or types of securities in accordance with their values or beliefs unless otherwise agreed by the Adviser in writing. Clients are welcome to set parameters on the Adviser’s limited discretionary authority in writing as to types of investments and amounts purchased or sold. Retirement Plan Rollovers: Haverdink Financial Management is a fiduciary to each of its clients and fiduciary duties apply to investment advice in connection with your retirement plan account or individual retirement account within the meaning of Title I of the Employee Retirement Income Security Act and the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way our firm earns compensation (asset-based fees for managed accounts) creates some conflicts with your interests, Therefore, we must operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. At the time of a rollover recommendation, we will provide you with a written disclosure discussing the reasons the rollover is in your best interests. Also, 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). * Provide basic information about conflicts of interests and fees while avoiding misleading statements about these topics 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 Where clients retain authority to implement recommendations, they are welcome to implement advice and recommendations, in whole or in part, via the financial services provider(s) of their choice. Certain clients may engage in client-directed transactions (investing on their own) and in such cases, the Adviser will not provide investment suitability and/or due diligence reviews or ongoing management services for these types of investments unless specifically agreed in writing. In the event the Adviser agrees to complete a client-directed transaction (as requested by a client), it will do so only as a value-added service for the client. D. WRAP FEE PROGRAMS Haverdink Financial Management does not participate in recommending wrap fee programs nor does the Adviser sponsor or act as a manager of a wrap fee program. E. AMOUNTS OF ASSETS UNDER MANAGEMENT Haverdink Financial Management’s assets under management as of the close of business on 12/31/2023, totaled $171,296,000 in 472 limited discretionary accounts. The managed assets are owned by individual investors and those meeting the definition of high-net-worth investors.