A. Shining Rock Advisors LLC (“Shining Rock” or “we”), founded in September 2020, is registered as an investment adviser with the SEC. Julie Claire Guest and Sage Barfield are principal owners of Shining Rock. B. Investment Advisory Services Shining Rock provides investment advisory services in accordance with each individual client’s needs. These services are discretionary except for services provided for any client investments in private offerings exempted from SEC registration under Rule 506 of Regulation D (“private investments”). Investment advisory services for any client assets held in private investments are provided on a non-discretionary basis. This means that while we continue an ongoing relationship with each client and seek to be involved in various stages of their lives and the decisions that are made, we will not seek specific approval of changes to the securities in client accounts, except for those securities that are private investments. Clients can make deposits or withdrawals in their accounts at any time. Because we exercise discretion when managing securities in accounts, except for those securities that are private investments, clients engaging us will be asked to execute a Limited Power of Attorney and an agreement that outlines the responsibilities of both the client and Shining Rock. The Limited Power of Attorney grants Shining Rock the discretionary authority over securities in client accounts, except for those securities that are private investments, but does not grant Shining Rock the authority to make any withdrawals or transfers in or out of a client account. Any withdrawals or transfers in or out of a client account will only be made at the specific direction of the client. Before engaging Shining Rock to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Shining Rock setting forth the terms and conditions of the engagement (including termination), describing the scope of services to be provided, the investment objectives of the account and the fee that will be deducted quarterly from the client’s account. If an Investment Advisory Agreement includes related clients (e.g. husband and wife, life partners, etc.), our services will be based upon the joint goals communicated to us by either party. We are permitted to rely upon instructions from either party with respect to disposition of assets, unless and until such reliance is revoked in writing to Shining Rock. Shining Rock is not responsible for any claims or damages resulting from such reliance or from any change in the status of the relationship between the clients. All services provided by Shining Rock on a fee-only basis. Shining Rock’s annual investment advisory fee is based upon a percentage of the market value of the assets placed under Shining Rock’s management. This fee is billed quarterly and is based upon the portfolio’s market value as determined by the client’s custodial firm on the last trading day of the preceding quarter. Shining Rock Advisors LLC, ADV Part 2A – Page 5 Miscellaneous Non-Investment Consulting/Implementation Services. To the extent specifically requested, Shining Rock may provide consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. Shining Rock does not serve as an attorney, accountant, or insurance agency, and no portion of its services should be construed as legal, accounting, or insurance brokerage services. Accordingly, Shining Rock does not prepare estate planning documents, tax returns, or sell insurance products. To the extent requested by a client, Shining Rock may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance agents, etc.). Clients are reminded that they are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by Shining Rock or its representatives. If the client engages any unaffiliated recommended professional and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e. attorney, accountant, insurance agent, etc.) and not Shining Rock, shall be responsible for the quality and competency of the services provided. Client Obligations. In performing its services, Shining Rock shall not be required to verify any information received from the client or from the client’s other hired professionals,

and is expressly authorized to rely thereon. Moreover, each client is advised that it remains the client’s responsibility to notify Shining Rock if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing/evaluating/revising Shining Rock’s previous recommendations and/or services. Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by Shining Rock independent of engaging Shining Rock as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Shining Rock’s initial and ongoing investment advisory services. Please also note that in addition to Shining Rock’s investment management fee described at Item 5 below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Shining Rock’s Chief Compliance Officer, Julie Claire Guest, remains available to address any questions that a client or prospective client may have regarding the above. Custodian Charges, Additional Fees. As discussed below in Item 12 below, when requested to recommend a broker‐dealer/custodian for client accounts holding publicly-traded assets, Shining Rock generally recommends that Charles Schwab & Co., Inc (“Schwab”) serve as the broker‐ dealer/custodian for client investment management assets. When requested to recommend a Shining Rock Advisors LLC, ADV Part 2A – Page 6 custodian for non-publicly-traded assets, Shining Rock generally recommends Inspira Financial Trust, LLC (“Inspira”). Broker‐dealers and custodians such as Schwab and Inspira charge transaction fees for effecting certain securities transactions. In addition to Shining Rock’s investment management fee referenced in Item 5 below, the client may also incur transaction fees to purchase securities for the client’s accounts. Portfolio Activity. Shining Rock has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Shining Rock will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Shining Rock determines that changes to a client’s portfolio are neither necessary nor prudent. Shining Rock’s investment management fee at Item 5 below shall remain payable during such periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Shining Rock will be profitable or equal any specific performance level(s). Disclosure Brochure. A copy of Shining Rock’s written Brochure as set forth on Part 2A of Form ADV shall be provided to each client before, or contemporaneously with, the execution of the applicable form of client agreement. C. Before providing investment advisory services, Shining Rock will ascertain each client’s investment objectives through data gathering and discussion with each client. If the client chooses to withhold information, the client must understand that comprehensive investment needs/objectives may not be fully considered. Investment decisions and ongoing account supervision are guided by the client’s stated individual needs, goals, objectives, time horizons, risk tolerance, and suitability. Shining Rock may recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private offerings exempted from SEC registration under Rule 506 of Regulation D (“private investments”), which may include debt, equity, and/or pooled investment vehicles when consistent with the client’s investment objectives. Shining Rock believes that client participation in the investment process is critical. Clients are advised to promptly notify Shining Rock if there are any changes in their financial situation or investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on Shining Rock’s services. D. Shining Rock does not participate in a wrap fee program. Shining Rock Advisors LLC, ADV Part 2A – Page 7 E. As of January 31, 2024, Shining Rock reports $129,600,000 discretionary assets and $31,100,000 non-discretionary assets under management.