Established in 2000 by President, Christopher Wick Jones, Carolina Financial Advisors, Inc., (the “Firm” “CFA” or us, we, our) is a North Carolina corporation and is a registered investment adviser in the State of North Carolina. CFA provides portfolio management services (or investment management services) on a discretionary basis. We also provide financial planning services to Clients (you, your). The portfolio management services include the following:
• Establishing investor goals;
• Developing an investment policy;
• Defining investment goals and the strategies required to attain them; and
• Making recommendations on asset allocation, selection of investments and portfolio management; CFA’s investment advisory services include an assessment of the Client’s specific investment goals, objectives, risk tolerances as distinguished from those of other Clients, including all relevant financial data (including, employment, income, tax bracket, family obligations, etc.). Financial Planning Services CFA provides financial plans that are based on the individual client’s financial, risk/reward objectives and tax status. The financial plans may be comprehensive or segmented. Typical planning engagements include:
• Planning for financial independence;
• Planning for major purchases;
• Education funding;
• Income and estate tax planning; and
• Family wealth preservation and transfer CFA’s financial planning services typically involve the review of a client’s overall financial situation, personal and financial goals, risk tolerance and objectives. Investment Policy The investment policy of CFA is preservation of principal. CFA’s priorities for account management include:
• Emphasize quality securities
• Diversify investments in keeping with the particular client’s investment plan
• Limit each security position as a percentage of the total portfolio Carolina Financial Advisors, Inc. Page 5
• Consider selling a portion of a position when it becomes too large a percentage of the portfolio
• Establish and maintain research coverage on securities and monitor price behavior
• Follow buy and sell points established by research
• Achieve the lowest average cost by building each position gradually according to fundamentals and market conditions
• Minimize transactions and commission costs through discounts or institutional rates
• Avoid speculation, aggressive trading, the new-issue market, options, tax shelters and non-liquid securities. The principal owner of Carolina Financial Advisors, Inc. is Mr. Christopher Wick Jones. Biblically Responsible Portfolio We offer Biblically Responsible portfolios for certain clients. The BRI portfolio consists of values-based investing that aligns investments with values. Biblically responsive investing further narrows values-based investing into companies that support traditional

Christian values. Given this, the portfolio may forgo some market opportunities available to portfolios that do not use an BRI criteria. The BRI factors may impact the portfolio’s exposure to other industries, sectors, and countries, which may impact its relative performance depending on market and economic conditions, and the portfolio’s performance may at times be better or worse than the performance of portfolios that do not use a BRI criteria. Participant Account Management (Discretionary) - Pontera We use a third party platform, Pontera, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Written Acknowledgement of Fiduciary Status When CFA provides investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money Carolina Financial Advisors, Inc. Page 6 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:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. As of December, 2023, Carolina Financial Advisors, Inc. managed $159,241,938.00 in discretionary assets and $15,736,278.00 non-discretionary assets.