ATON Financial LLC is a registered investment advisor firm registered with the U. S. Securities and Exchange Commission (“SEC”) since April 2018. Prior to that, the firm was registered with the Puerto Rico securities regulators since February 2015. The principal owners of ATON Financial LLC are Marko Rendic, CFA, Managing Member and Dionisio Trigo, Investor. Advisory Services ATON Financial LLC’s (“ATON” or “Advisor”) principal service is providing fee-based investment advisory services and financial planning services. The Advisor practices custom management of portfolios, on either a discretionary or non-discretionary basis, according to the client’s objectives. The Advisor’s primary approach is to use a tactical allocation strategy aimed at reducing risk and increasing performance. The Advisor may use any of the following: exchange listed securities, over-the-counter securities, foreign securities, corporate debt securities, commercial paper, CDs, variable annuities, municipal securities, mutual funds, and United States government securities to accomplish this objective. The Advisor measures and selects mutual funds by using various criteria, such as the fund manager’s tenure, and/or overall career performance. The Advisor may recommend, on occasion, redistributing investment allocations to diversify the portfolio in an effort to reduce risk and increase performance. The Advisor may recommend specific stocks to increase sector weighting and/or dividend potential. The Advisor may recommend employing cash positions as a possible hedge against market movement which may adversely affect the portfolio. The Advisor may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of client, or any risk deemed unacceptable for the client’s risk tolerance. Selection of Other Money Managers ATON may recommend and refer clients to unaffiliated money managers or investment advisors through Managed Account programs sponsored by a third-party provider. In these arrangements, the client will then enter into a program and investment advisory agreement with the program sponsor and third-party money managers. ATON will assist and advise the client in establishing investment objectives for the third-party money managers and continue to provide oversight of the client account and ongoing monitoring of the activities of the third-party money managers. The third-party money managers will develop an investment strategy to meet those objectives by identifying appropriate investments and monitoring such investments. In consideration for such services, the program sponsor will charge a program fee that includes the investment advisory fee of the third-party money managers, the administration of the program and trading, clearance and settlement costs. The program sponsor will add ATON 's investment advisory fee (described below in Item 5) and will deduct the overall fee from the client account quarterly in arrears based on the fair market value at the end of the preceding quarter. The asset-based program fee will depend on factors such as the size of the account, the asset class of the underlying securities and the third- party money managers selected. ATON will ensure that all third-party money managers recommended to clients will be either an investment advisor registered with the Puerto Rico Securities Commission, the Securities and Exchange Commission, or exempt from such registrations. The client, prior to entering into an agreement with a third-party money manager selected by ATON, will be provided with that manager’s Brochure. In addition, ATON and its client will agree

in writing that the client’s account will be managed by that selected third party money manager on a discretionary basis. Financial Planning In addition to investment supervisory services, ATON may provide Financial Planning Services to some of its clients. The Advisor’s Financial Planning services may include recommendations for portfolio customization based on their client’s investment objectives, goals and financial situation. Financial Planning Services may also include recommendations relating to investment strategies as well as tailored investment advice, and estate planning services. Qualified Retirement Plan Consulting Services ATON will evaluate the Plan and its operation including its: Trustee, custodial and recordkeeping arrangement; design; fiduciary compliance program; costs and fees associated with investments and service providers; required and elective contributions; employee communication and education program, and; investment selection and monitoring process, including its investment policy statement, hereinafter referred to as the “IPS”. With regard to the IPS, the Advisor will assist the Plan Sponsor in adopting a suitable IPS, amending it from time to time, and will provide information and recommendations, consistent with the IPS, to aid the Plan Sponsor in selecting and monitoring investments offered to Participants in the Plan. Information and recommendations will be based on data as of the end of each calendar quarter. Within a reasonable period of time following each calendar quarter, the Advisor will provide the Plan Sponsor with a written report detailing, at a minimum, all costs and fees associated with investments and operation of the Plan, and information and recommendations, consistent with the IPS, for the Plan Sponsor's selection, removal and replacement of investments offered to Participants in the Plan. The Advisor’s asset management fee (described below in Item 5) will be calculated based on assets in the Plan at the end of the quarter, added to the Plan Administrator’s fee, and charged to the Plan by the Plan Administrator in accordance with the agreement between the Plan Sponsor and the Administrator. The Administrator will remit the Advisor’s portion of the fee to the Advisor. The Advisor's roles and actions in fulfilling all responsibilities pertaining to this Agreement shall not include those of the Plan's Trustee, and will be performed solely at the direction of the Plan Sponsor, its authorized officers, employees and/or agents. At no time will the Advisor accept, maintain possession of, or have custodial responsibility for, the Plan's assets. The Advisor will not conduct or effect the purchase or sale of any assets of the Plan on behalf of the Plan Sponsor or Plan Participants. The Advisor will not advise, in any manner, any Participant, person or entity related to the Plan other than the Plan Sponsor. Communicational and educational activities in which the Advisor engages related to Participants in the Plan shall be solely at the direction of the Plan Sponsor, and shall not be represented by the Advisor or Plan Sponsor as investment, tax or legal advice. The Advisor is not licensed to provide, shall not provide, nor be construed to provide, the services of an attorney or accountant. ATON will tailor its advisory services to its client’s individual needs based on meetings and conversations with the client. If clients wish to impose certain restrictions on investing in certain securities or types of securities, the Advisor will address those restrictions with the client to have a clear understanding of the client’s requirements. ATON does not provide portfolio management services to wrap fee programs. As of February 15, 2023, ATON had the following client assets under management: Discretionary $296,668,000 Non-discretionary 132,212,000 Total $428,880,000