A. Adero Partners, LLC (“Adero”) is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Adero is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Adero is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Adero. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Adero is managed by James Knight, Michael Spector, Eric Swensen, Aaron White, Gregory Warner, Jayne Smith, Sarah Robinson, and Mark Bates, (“Adero Principals”), pursuant to a management agreement between Cambridge Partners, LLC and Adero Partners, LLC. The Adero Principals serve as leaders and officers of Adero and, in that capacity, are responsible for the management, supervision and oversight of Adero. B. Adero offers clients discretionary investment management, financial planning, and other consulting services as discussed in more detail below. INVESTMENT MANAGEMENT SERVICES Adero’s annual investment management services include, to the extent requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined at the sole discretion of Adero), Adero may determine to charge for these additional services pursuant to a stand-alone Financial Planning and Consulting Agreement. Before engaging Adero to provide planning or consulting services, clients are required to enter into an Investment Advisory Agreement with Adero setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client. To commence the investment management process, Adero representatives consult with clients to discuss their financial condition, investment experience, time horizon, risk tolerance level, income requirements, and other relevant factors. Adero representatives then help clients develop investment objectives, individualized investment guidelines, and an asset allocation strategy. Adero supervises account transactions on a continuous basis, and each client’s portfolio holdings and asset allocations are monitored on at least a quarterly basis. CONSULTING SERVICES (STAND-ALONE) Adero may provide consulting services on investment and non-investment-related matters on a stand-alone separate fee basis. Clients are required to enter into a separate agreement with Adero setting forth the terms and conditions of the engagement. In certain circumstances, Adero personnel may be engaged to assist in the preparation and filing of client tax returns for a set fee in addition to any other service, when agreed upon in writing. Additionally, when appropriate as part of the financial planning process, Adero may recommend the use of an independent third party estate planning tool for an additional set fee, when agreed upon in writing. If requested by the client, Adero may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of Adero in these instances or any other recommended professional. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from Adero. Adero does not serve as a law firm, accounting firm, or insurance agency, and no portion of its services should be viewed as legal, accounting, or insurance implementation services. Accordingly, Adero does not prepare estate planning documents or sell insurance products. However, to the extent requested by a client, Adero may recommend the services of other professionals for implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). The client is under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from Adero. If the client engages any recommended professional, and a dispute arises from that engagement, the client agrees to seek damages exclusively from the engaged professional. OTHER Adero is a fiduciary under the Employee Retirement Income Securities Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan participants. Adero is also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, Adero is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE.”) As a fiduciary, we have duties

of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Adero may provide investment advice about private investment funds, and may also recommend, on a non-discretionary basis, that certain qualified clients consider an investment in private investment funds. Adero’s role relative to the private investment funds will be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) will be included for purposes of Adero calculating its annual investment advisory fee. Adero clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). While Adero may recommend allocating investment assets to private investment funds that are not available directly to the public, Adero may also recommend that clients allocate investment assets to publicly available mutual funds and exchange-traded funds (“ETFs”) that the client could obtain without engaging Adero as an investment adviser. If a client or prospective client determines to allocate investment assets to publicly available mutual funds or ETFs without engaging Adero as an investment adviser, the client or prospective client would not receive the benefit of Adero’s initial and ongoing investment advisory services. Certain mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”), are only available through professional intermediaries like registered investment advisers. Adero may allocate client investment assets to DFA mutual funds. Upon the termination of Adero’s services, clients may be restricted in transferring or purchasing additional shares of DFA mutual funds or similarly restricted mutual funds. Adero may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). The client may be required to enter into a separate agreement with the Independent Manager(s), which will set forth the terms of the client’s engagement with the Independent Manager(s). In these situations, the Independent Manager(s) will have day-to-day responsibility for the active discretionary management of the allocated assets. Adero will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. The factors Adero considers in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, Adero’s advisory fee as set forth in Item 5. We implement investment advice on behalf of clients in certain held-away accounts – for example, 401(k) or 529 plan accounts – maintained either at the custodians with whom we have an institutional relationship or at other independent third-party custodians. We have the capability to review, monitor, and manage these held-away accounts in a fashion similar to the way in which we review, monitor, and manage accounts that are not held away. We have business arrangements with SCS Capital Management LLC (“SCS”) and Origin Investments Group, LLC (“Origin”), which are indirect, wholly-owned subsidiaries of Focus LLC, under which certain clients of Adero have the option of investing in certain private investment vehicles managed by SCS or Origin. Adero is an affiliate of SCS and Origin by virtue of being under common control with them. Please see Items 5, 10, and 11 of this Brochure for further details. Additionally, we help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information. C. Adero provides investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client's investment objective(s). Thereafter, Adero allocates and/or recommends that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Adero services. Clients may impose reasonable restrictions on the management of their accounts if Adero determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Adero’s management efforts. In performing its services, Adero is not required to verify any information received from the client or from the client’s other professional advisors and is expressly authorized to rely thereon upon. Under all circumstances, clients must promptly notify Adero of any change in their financial situation or investment objectives that would necessitate a review, evaluation or revision by Adero of previous recommendations and/or services. D. Adero does not participate in a wrap fee program. E. As of December 31, 2023, Adero maintained approximately $4,035,668,036 in client assets under management, with $4,008,672,908 being managed on a discretionary basis.