SPP was formed in November 2014 by its principal Craig R. Sutherland, to offer investment management and planning services to its clients. Prior to SPP rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with SPP setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). While this brochure generally describes the business of SPP, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on SPP’s behalf and is subject to the Firm’s supervision or control. As of December 31, 2023, SPP’s assets under management were $123,129,238, of which $94,536,511 were on a discretionary basis, and $28,592,727 were on a non-discretionary basis. Additionally, SPP had $91,233,174 in assets under advisement through two sub-advisory relationships as of December 31, 2023. Investment Management Services SPP manages client investment portfolios on a discretionary basis within a pre-established and agreed upon investment policy statement for each client relationship. As part of an investment management offering, SPP may provide clients with certain investment planning advice and guidance. SPP will also offer subadvisory services to other investment management firms in certain circumstances, providing timely information regarding the account construction for investment strategies. All trading instructions to the custodian for subadvised accounts will be the sole responsibility of the investment advisory firm retaining SPP as subadviser. In providing its advisory services, SPP is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. SPP always recommends that clients engage other legal and tax professionals to review, coordinate, and implement all changes to their financial plans ancillary to their investment planning process. Clients retain absolute control over all planning decisions and

are under no obligation to act upon any of the planning suggestions and recommendations made by SPP. SPP primarily allocates clients’ assets among various exchange-traded funds (“ETFs”), index funds, mutual funds, and individual debt securities in accordance with their stated investment objectives. SPP generally limits its investment advice to mutual funds, fixed income securities, real estate funds, equities, ETFs, treasury inflation protected/inflation linked bonds and non-U.S. securities. SPP may use other securities as well to help diversify a portfolio when applicable. SPP tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. SPP consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify SPP if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Written Acknowledgement of Fiduciary Status When we provide 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 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.