A. Description of the Advisory Firm Impact Capital, LLC (hereinafter “IC”) is a Limited Liability Company organized in the State of Maryland. The firm was formed in May 2018, and the principal owners are William D. Bancroft and ECDC Investments, LLC, which in turn is owned by Eric Cohen and Daniel Cohen. B. Types of Advisory Services Portfolio Management Services IC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. IC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring IC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. IC will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. IC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of IC’s economic, investment or other financial interests. To meet its fiduciary obligations, IC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, IC’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is IC’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Pension Consulting Services IC offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: o identifying investment objectives and restrictions o providing guidance on various assets classes and investment options o recommending money managers to manage plan

assets in ways designed to achieve objectives o monitoring performance of money managers and investment options and making recommendations for changes o recommending other service providers, such as custodians, administrators and broker-dealers o creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning, executive compensation, charitable giving and risk management. The goal of offering this service is to provide clients with a comprehensive financial plan designed to show them where they are and get them where they want to go. Services Limited to Specific Types of Investments IC generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities and non- U.S. securities. IC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions IC will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by IC on behalf of the client. IC may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent IC from properly servicing the client account, or if the restrictions would require IC to deviate from its standard suite of services, IC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. IC does not participate in wrap fee programs. E. Assets Under Management IC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $188,079,548.00 $0.00 December 2023