Firm Description Beese, Fulmer Investment Management, Inc. was founded in 1980. Dennis S. Fulmer is the Chairman and owns the majority of the corporation. The other shareholders are Ryan T. Fulmer and Nicholas T. Perini. Beese, Fulmer Investment Management, Inc. provides personalized confidential investment management to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and corporations on a discretionary and non- discretionary basis. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, college planning, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. We do not act as a custodian of client assets. The client always maintains asset control. BFIM places trades for clients under a limited power of attorney. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they occur. Beese, Fulmer Investment Management, Inc. is strictly a fee-only investment management firm. We do not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. We are not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. Types of Advisory Services Beese, Fulmer Investment Management, Inc. provides confidential professional investment management services on both a discretionary and a non-discretionary basis. We offer investment advice on the following investment vehicles:
• Exchange-listed securities
• Securities traded over-the counter
• Foreign Issuers
• Exchange Traded Fund
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of Deposit
• Municipal Securities
• Mutual Funds
• Collective Investment Trusts
• U.S. government securities
• Options contracts on securities
• Interests in partnerships investing in: 1) Real estate 2) Oil and gas interests 3) Master Ltd. Partnership in operating companies BFIM may provide financial planning by evaluating a client’s financial state using currently known variables to predict future cash flows and asset values. Information is gathered through personal interviews and completed questionnaires. In isolated cases, BFIM provides investment advice through consultations.
• Consults are billed at an agreed upon hourly rate
• BFIM does not maintain any supervision over the assets on which the consultation was provided
• The decision to buy/sell any securities discussed during the consultation is made by the person(s) who requested the consultation Beese, Fulmer Investment Management, Inc. publishes an Investment Outlook quarterly. It is distributed to

clients, prospects, attorneys and accountants and other professionals at no charge. When we provide investment advice to you regarding your retirement plan account or individual retirement plan 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 interest ahead of yours when making recommendations (give loyal advice)
• Avoid misleading statements about conflicts of interest, fees, and investments
• Follow policies and procedures designated 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. Beese Fulmer manages Employee Retirement Income Security Act of 1974, as amended (“ERISA”), assets in the Beese Fulmer Quality Equity Fund a collective investment trust (“CIT”) created in November of 2023. The CIT is bank maintained and not registered with the Securities and Exchange Commission. The CIT is not a mutual fund registered under the Investment Company Act of 1940, as amended (“1940 Act”), or other applicable law, and unit holders are not entitled to the protections of the 1940 Act. The regulations applicable to the CIT are different from those applicable to a mutual fund. The CIT’s units are not securities registered under the Securities Act of 1933, as amended, or applicable securities laws of any state or other jurisdiction. Beese Fulmer has engaged a third‐party service provider, Chicago Clearing Corporation (CCC), to monitor and file securities claims class action litigation paperwork with claims administrators on behalf of the Firm’s clients. When a claim is settled and payments are awarded to Beese Fulmer clients, it may be necessary to share client information, such as name and account number, with CCC in connection with this service. Beese Fulmer does not receive any fees or remuneration in connection with this service nor does it receive any fees from the third‐party provider(s). CCC earns a fee based on a flat percentage of all claims it collects on behalf of Beese Fulmer clients. This fee is collected and retained by CCC out of the claims paid by the claims administrator. Clients may opt out of this service at any time. If a client opts out, Beese Fulmer does not have an obligation to advise or take any action on behalf of a client with regard to class action litigation involving investments held in or formerly held in a clientʹs account. As of December 31, 2023, Beese, Fulmer Investment Management, Inc. managed approximately $1.32 billion in assets for approximately 1,170 accounts. All of our assets are managed on a discretionary basis.