RPJ was founded in October 2019. RPJ is wholly owned by Sandy Spring Bank, a Maryland corporation. Sandy Spring Bank is wholly owned by Sandy Spring Bancorp, Inc., a Maryland corporation. SSB is the holding company for Sandy Spring Bank, and its principal subsidiaries RPJ and West Financial Services Inc, (“WFS”). RPJ is a fee-only investment adviser registered with the SEC that provides investment advisory and financial planning services to individuals, high net worth individuals, retirement and profit sharing plans, charitable organizations, and corporations and other business entities. RPJ’s investment philosophy stresses diversified portfolios tailored to each client’s individual circumstances and specific goals using the processes described below. RPJ’s investment management goal is to optimize the return on each client’s portfolio while keeping within the individual’s risk tolerance, time horizon, and tax and wealth objectives. Descriptions of the services offered by RPJ appear below. Investment Management Services When providing investment management services (“Investment Management Services”), RPJ generally develops with each client an understanding of the client’s financial circumstances, goals, risk tolerance level, and investment objectives and guidelines based on information provided by the client. Based on this review of information, RPJ will develop asset allocation guidelines for the client. RPJ will periodically re-evaluate the client’s asset allocation guidelines and, as appropriate, gather additional information about the client’s financial circumstances, goals, risk tolerance, and investment objectives and guidelines. RPJ meets with clients periodically, including quarterly, annually, or any time on an as-needed basis. Clients may make written requests for restrictions on their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Clients should note, however, that requested restrictions must be agreed to by RPJ and, if agreed to, may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that RPJ manages clients individually, so portfolio composition and performance with the same investment objectives, goals and/or risk tolerance may differ. Portfolio Management Services RPJ offers to manage individual and institutional client accounts on both a discretionary and non- discretionary basis. Discretionary Services When engaged to provide discretionary services, RPJ has the authority to supervise and direct the portfolio without prior consultation with the client. Clients engaging RPJ on a discretionary basis will be asked to execute a Limited Power of Attorney (through an IMA (defined below) and custodian agreement) granting RPJ the discretionary authority over the client accounts, as well as an investment management agreement (“IMA”) that outlines the responsibilities of both the client and RPJ. Non-Discretionary Services While new clients typically engage RPJ to manage client investment portfolios on a discretionary basis, clients may choose to have their investment portfolios managed on a non-discretionary basis. Clients who choose a non-discretionary arrangement will be contacted prior to the execution of any trade in the account(s) under management to approve the transaction. This may result in a delay in executing, or prevent the execution of, recommended trades either because the client does not respond in a timely manner, or because the client does not consent to the trade, either of which could adversely affect the performance of the portfolio. Upon request, each client may receive written or electronic confirmations from the client’s account custodian after any changes are made to the client’s account. Each client will also receive not less than quarterly statements from the client’s account custodian. Retirement and Other Special Investment Accounts For some clients, RPJ may manage investment accounts outside of the clients’ regular portfolio custodians, such as variable life insurance and annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (e.g., 529 plans). In these situations, RPJ may make non-discretionary recommendations or, with appropriate arrangements, discretionary decisions, among the various investment options that are available with the investment accounts. Financial Planning Services RPJ provides financial planning services (“Financial Planning Services”) to clients through a five- step process that includes identifying goals, analyzing data, providing recommendations, assisting with implementation,

and periodically reviewing projected outcomes. Financial Planning Services typically start with a review of the client’s balance sheet to determine net worth and titling of assets. RPJ then typically reviews, among other things, cash flow, income taxes, investments, historical performance and personal risk tolerance before determining portfolio allocations and suitable investment selections. Financial Planning Services may also include a detailed review of, and recommendations with respect to, one or more of the following areas, as determined by RPJ and the client:
• Insurance
• Income tax
• Cash management
• Education funding
• Retirement goals
• Special needs
• Planned giving
• Stock option exercise strategies
• Business form and succession planning
• Other financial areas as mutually agreed upon by RPJ and the client After completing RPJ’s financial planning analysis for a client, RPJ meets with the client to review a recommended financial plan and discuss implementation of the same. Financial plans may, but are not always, reduced to a written document. Each financial plan is intended to be a suggested blueprint of how to meet the client’s individual goals, so different clients with similar profiles may have different financial plans. Each client will determine whether or not to implement recommendations made by RPJ as part of the Financial Planning Services. If requested, RPJ will work with a client’s selected professionals (e.g., accountants and attorneys). However, where requested, RPJ will recommend professionals from RPJ’s network. Clients are under no obligation to engage the services of any professional RPJ recommends, but if the client engages a recommended professional and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. RPJ encourages clients to call at any time with financial questions and concerns, and recommends an annual meeting to discuss changes in circumstances and goals. Upon request, RPJ may involve multiple generations in Financial Planning Services to facilitate family financial planning. Because potential conflicts of interest exist with the exchange of intergenerational information, RPJ attempts to minimize these conflicts by treating each household as its own fiduciary relationship. RPJ will only share information across households with each household’s consent. In addition to individual and family clients, RPJ provides consulting services for institutional clients, which may include: creating, reviewing, and monitoring investment policy statements, investment portfolios, and cash management, as well as special needs related to fiduciary education, succession planning and investment management training. Business Consulting Services RPJ’s business consulting services may include cash flow analysis, finance sourcing, establishment of business retirement plans, development of exit strategies, and other requests specific to each client. Retirement Plan Consulting Services RPJ provides retirement plan consulting services to plan sponsors (“Retirement Plan Sponsors”) which may include, but are not limited to:
• Evaluation of existing plan to determine, among other things, breadth of features, cost structure and robustness of investment options available to participants.
• Creation of a new company retirement plan that includes consideration of features to be part of the plan such as, but not limited to, Roth options, company matches, profit sharing, vesting schedule, participant loans, investment options, and allocation of investment and administrative costs between company and participants.
• Transition from an existing company retirement plan to a new retirement plan.
• New (or transition) retirement plan investment advisory services:
• Plan investment policy statement
• Plan investment option selection
• Plan investment option monitoring
• Plan features and benefits review to existing and new participants
• Investment education to participants
• Investment advice to participants Creation of new retirement plans are provided jointly by RPJ and Retirement Plan Consultants (“RPC”). RPC assists with initial set up of the plan and administrative functions and an affiliate of RPJ creates the initial investment policy statement for the plan. RPJ serves as the adviser to the plan sponsor and assists with the selection and monitoring of investments and education. Assets Under Management As of December 31, 2023 RPJ had approximately $728,440,402.78 in discretionary assets under management and $1,392,128,494.48 in non-discretionary assets under management.