We believe that many, if not all, of the “money concerns” and investment/product focuses and worries clients tend to stem from a lack of confidence and understanding of their true financial picture now and going forward. –We aim to bring clarity and confidence to this issue in the form of a concrete, regularly reviewed and updated financial plan that focuses on the path to their desired way of life. We will interview and consult with each client to determine the client’s personal financial situation and objectives and to analyze the client’s financial documentation. As applicable, we then review the client’s assets and liabilities, investment portfolio, retirement plan, education plan, risk management plan, risk tolerance, and estate plan, as well as other areas relevant to the client’s financial health. We will then build a model for the client that covers some or all of the above. This usually leads to a series of recommendations for action to improve the client’s plan to give them more chance of meeting their objectives. Our clients are based across the US and therefore we provide our services on a remote basis – via email, telephone, web meetings etc. and are available to work with the client throughout the year to implement the plan. We do occasionally travel to meet clients, but this is not part of the formal service proposition. The client is ultimately responsible for communicating changes in circumstances to PFW so that we can provide the most accurate advice and counsel possible. We are available year-round to assist with the implementation of the plan and to answer any client questions, but the client is ultimately responsible for the implementation or rejection of our recommendations. Clients are never obligated or required to implement our recommendations. Services Limited to Specific Types of Investments PFW generally limits its investment advice to mutual funds and ETFs. PFW may use other securities as well, to help diversify a portfolio when applicable. International Pension Schemes Many of the clients in the market we serve (British expatriates living throughout the USA) have various legacy pensions in the UK. One of the key services we provide is consultancy and administration support in understanding the options clients have as US residents and the different implications of a transfer. Of the solutions available to them to transfer their UK pensions, we support and provide advice on: Qualifying Recognised Overseas Pension Scheme (QROPS) A Qualifying Recognised Overseas Pension Scheme, or QROPS is an overseas pension scheme that meets certain requirements set by Her Majesty's Revenue and Customs (HMRC). A QROPS must have a beneficial owner and trustees, and it can receive transfers of British pension benefits. Due to a change in the tax treatment of QROPS in the UK, PFW does not participate in the transfer of UK pensions into QROPS. However, PFW will continue to service existing QROPS arrangements. Additional investments cannot be added to existing QROPS. Self-Invested Personal Pension (SIPP) A Self-Invested Personal Pension (SIPP) is the name given to the type of UK government-approved personal pension scheme, which allows individuals to make their own investment decisions from the full range of investments approved by HMRC. If in the best interest of the client, PFW will recommend that clients transfer their UK pension assets to a SIPP. PFW does not maintain custody of pension assets. All pension assets are administered by a regulated pension trustee (authorized by the relevant financial services regulator where the pension plan is held) and subject to the terms and conditions of a separate agreement between Client and the pension trustee. Current QROPS trustees are STM Malta Trust and Company Management Limited (“STM”) and Trireme Pension Services (Malta) Limited (“Trireme”). Current SIPP trustees are London & Colonial (“L&C”), (L&C are part of the STM Group), iPensions Limited, Novia Global Ltd (“Novia SIPP”), MES Pensions (“MES SIPP”) and Morningstar Retirement Solutions Ltd (“Morningstar SIPP”). QROPS and SIPP assets are held in custody by the Client’s selected custodian and subject to the terms and conditions of a separate agreement between the Client’s trustee and the custodian. Other QROPS and SIPP providers may be available through other investment advisers under different arrangements, including but not limited to applicable fees and charges, and residency requirements. Clients are strongly encouraged to review their agreements with their pension trustees and any and all other disclosure materials provided by the pension trustees and the custodian for a full understanding of the services provided and any associated costs therein. Pension plan statements and other reports are generally sent directly to Clients on at least an annual basis. Clients are encouraged to review such material carefully for a complete understanding of the services offered and the costs associated with the management of such pension plans. PFW encourages questions regarding services, fees, and other associated issues be addressed with Firm personnel directly. Tax and Accounting Matters PFW does not provide any tax advice including, without limitation, in relation to any US tax reporting requirements and/or other tax implications arising in relation to Clients’ pension transfers. Although from time to time we may inform Clients of tax developments, we recommend that Clients seek their own tax advice, including in relation to procedures under tax treaties between the United States and the UK (or other applicable jurisdiction) for the avoidance of double taxation on their UK/EU pension arrangements. PFW can introduce Clients to completely unaffiliated tax advisers who have experience in US/UK matters. Clients are under absolutely no obligation to use a tax adviser that we introduce. PFW receives no financial remuneration from any tax adviser we recommend to clients. PFW can work with Client’s chosen tax adviser, should that be preferred. PFW has entered into a partnership with Optimise Accountants, a UK-based cross-border tax and accounting firm. This partnership allows us to offer a comprehensive, integrated range of tax and accounting services tailored to the client’s needs. The partnership has been established to fulfill the commitment to our clients’ financial needs, that include proper tax and accounting services and consultation. Clients and Optimise will enter into a separate agreement and payment for services outside of the services and fees paid to PFW. Clients are not required to engage Optimise for these services and may find similar services at a lower cost. Estate Planning Our firm offers basic estate planning services to our clients that consists of education on estate planning topics and the collection of general information necessary to complete a new estate plan or update a current estate plan. The

estate planning solution is best suited for expatriate families with relatively straightforward situations, and/or as a stopgap for an expatriate before they commit the time and resources to a more comprehensive estate plan. If we determine that your situation is more complex, we can recommend other solutions with UK/US estate planning attorneys to address your estate planning needs. Clients are not required to utilize a third-party service that we may recommend, and they may receive similar services from other professionals at a similar or lower cost. Our firm utilizes the services of Estate Guru, a third-party estate planning service for clients who have the need for estate planning review, creation or updates. Please note that this is a separate service that comes at a fee separate and in addition to any advisory/financial planning fees. The fee associated with the service will be in addition to the fees that clients may already pay and is disclosed in Item 5, and within the PFW Estate Planning Disclosure Document that clients receive before engaging in this service. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title 1 of the Employee Retirement Income Act (ERISA) and the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: (1) Meet a professional standard of care when making investment recommendations (give prudent advice); (2) Never put our financial interests ahead of yours when making recommendations (give loyal advice); (3) Avoid misleading statements about conflicts of interest, fees, and investments; (4) Follow policies and procedures designed to ensure that we give advice that is in your best interest; (5) Charge no more than a level fee that is reasonable for our services; and (6) Give you basic information about conflicts of interest. PFW offers the same investment strategies to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. PFW participates in a wrap fee program for assets custodied at Betterment, a third-party sub-adviser. Betterment for Advisors offers its investment sub-advisory services for traditional securities portfolios through a wrap fee program that includes custody and trading services provided by its affiliate, Betterment Securities. Betterment for Advisors is a digital wealth management platform generally serving independent investment advisory firms and advisors (such advisors, “you” or “Advisor”). Betterment LLC (“Betterment”), a registered investment advisor, serves as sub-advisor to Advisor’s clients (“Clients”). MTG LLC, dba Betterment Securities (“Betterment Securities”), a registered broker-dealer and member of FINRA and SIPC, serves as broker-dealer and custodian. See Appendix A to this brochure for more information. Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $987,008 $113,426,513 31 December 2022 C. Client Tailored Services and Client Imposed Restrictions E. Assets Under Management D. Wrap Fee Programs 9 PFW’s fees vary depending upon the services you receive. PFW charges the following types of fees: Fixed fees and portfolio management fees. Portfolio management fees are a percentage of the assets that you have directed us to manage. (See Fee Schedule below.) Fixed fees are either financial planning fees, and or account setup fees, (See Fixed Fees below.) Lower fees for comparable services may be available from other sources. PFW charges upfront flat setup fees (“setup fees”) and portfolio management fees (“management fees”) at the annual rates shown below, which are expressed as a percentage of Client assets under management. US-Based Non-US Based TradePMR & Betterment4 Sub-Advised Funds on Morningstar1,2 SIPPs on Novia Global, MES & Morningstar2 Novia QROPS & Legacy QROPS on RL360 or Utmost Setup Fee (see section on Account Setup Fees on the following pages) None £2,000 For Defined Contribution Pension and SIPP Transfers: £3,500 + £1,000 per additional pension For Defined Benefit Pension Transfers: £8,500 + £1,000 per additional pension Ongoing Fee Flat Per Annum of 1.25% p.a.3 1Ongoing fee for Morningstar Accounts is the sum of the PFW fee (0.75%) and the sub-adviser fee (0.50%). Sub-advisers include LGT Vestra US and Dunhill Financial. 2Members of the same household may be eligible for reduced set up fees rather than individual pricing shown. 3The ongoing fee is negotiable at the sole discretion of the Adviser. 4Betterment accounts are subject to a wrap fee of 0.20%. Please see Appendix A to this brochure for more information. Billing Procedures US-Based Non-US Based TradePMR & Betterment Morningstar (GIAs, ISAs, SIPPs) Novia Global, MES & Morningstar Wealth RL360 or Utmost Billing Cycles Billed monthly in arrears Billed monthly in arrears Billed monthly in arrears Trustee invoiced biannually (i.e. every 6 months) in advance Fee Payments Directly debited from the Account by PFW Directly debited from the Account by custodian Directly debited from the Account by custodian Directly debited from the account by the trustee Fee Calculation Average of daily balance in account throughout the billing period Daily values of account, totaled for the billing period Value of the account as of the last day of the billing period Value of the account statement downloaded during the first five business days of the billing period4 4 PFW will download valuation statements for Legacy QROPS directly from the custodian during the first 5 business days of the billing period (and will submit an invoice for our fee to the QROPS trustee shortly thereafter). Unit prices may reflect an earlier date than the valuation statement date. A. Fee Schedule