Item 5: Additional Compensation ................................................................................................. 32 Item 6: Supervision ....................................................................................................................... 32 Firm Description and Types of Advisory Services Assabet Advisors, LLC (“Assabet,” “we” “us,” “ours” or the “Firm”) began business as a registered investment advisor in September 2003. We have sought to provide customized investment solutions to clients using a largely scientific approach to investing. Wayne M. Ushman is the owner of Assabet. We provide investment management and consulting services. Before entering into an advisory relationship with us, a client is required to enter into one or more written agreements with us (together the “Agreement”) which describe the terms and conditions governing the provision of services. Neither Assabet nor the client may assign the Agreement without the consent of the other party. A transaction that does not cause a change of actual control is not considered an assignment. Types of Advisory Services We reserve the right to advise clients on any other type of investment that it deems appropriate based on the client’s stated goals and objectives. We may also provide advice on any type of investment held in a client’s portfolio at the inception of the advisory relationship or on any investment on which the client requests advice. Investment Management Services Our investment advisory services are generally limited to the discretionary management of investment portfolios on behalf of our clients, consistent with the individual objectives of the portfolio owners. We may, under certain circumstances, offer non-discretionary management services. As a part of the investment management relationship, we may discuss non-investment related financial decisions or concerns with clients, recommending other advisors such as attorneys, accountants or insurance specialists. We allocate client investment assets primarily among mutual funds, exchange-traded funds (“ETFs”) and individual debt securities in accordance with the investment objectives of the client. We may, on rare occasion, recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities which may include debt, equity, and/or pooled investment vehicles as consistent with the client’s investment objectives. We also may offer non-discretionary investment management services to clients concerning variable life or annuity products they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that are not held by the client’s primary custodian. In doing so, we recommend the allocation of client assets among various investment options available through the product, leaving it up to the client to make ultimate decisions or to implement the recommendations. We respond to client needs by customizing our advisory services. We typically consult with clients at the initiation of the client relationship, and on an ongoing way, to create an Investment Policy Statement (“IPS”) to record the factors guiding the investment

strategy as well as the respective duties of Assabet and the client during the relationship. The IPS will include such information as the investment time horizon, the portfolio’s primary purpose and objective, the client’s risk tolerance, acceptable investment vehicles, and general asset allocation targets. ERISA Retirement Plan Advice We provide investment advice to sponsors of ERISA retirement plans. At the plan level, we are the responsible plan fiduciary for the analysis, selection, and monitoring of the investment portfolio for each plan participant. Tailored Relationships We tailor investment advisory services to the individual needs of the client. Clients are advised to promptly notify us whenever there are changes in their financial situation or investment objectives. Clients may impose reasonable restrictions on the upon our management services. All limitations and restrictions placed on accounts must be presented to us in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs We do not participate in a Wrap Fee Program. Client Assets As of December 31, 2022, we had $126,155,317 in assets under management. Of that amount, $123,235,078 were managed on a discretionary basis and $2,920,239 on a non-discretionary basis.