Firm Description Middleton & Company, Inc. (“Middleton”) is an independent investment counseling firm dedicated to providing objective advice and disciplined investment management to individuals, families, trusts, endowments, foundations, and ERISA and retirement plans. Our firm was founded on the belief that experienced investment professionals, applying sound judgment and thorough market analysis, can make a difference in clients’ lives. Middleton is a duly formed corporation in the Commonwealth of Massachusetts that has been offering investment advice to clients since 1984. As of December 31, 2023, Middleton manages $1,040,712,499 in assets under management on a discretionary basis and $8,186 on a non-discretionary basis. The principals of our firm are Managing Director and President, John K. Sargent, Jr.; Managing Director and Chairman of the Board, Alice K. Walsh; Managing Director and Chief Compliance Officer, Maria McCormack; and Robert G. Bruch, Jr., Managing Director and Chief Investment Officer. Middleton is exclusively employee owned; the Middleton & Company Employee Stock Ownership Trust is our majority shareholder. As used in this brochure, the words "we", "our" and "us" refer to Middleton and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's owner(s), employees, and all individuals providing investment advice on behalf of our firm. Types of Advisory Services Offered Middleton provides comprehensive investment advice designed to meet the specific goals and needs of our clients. Our advisory services include consultations to establish investment objectives; account reviews; purchases and sales of securities; and portfolio appraisals. Advice is typically provided on a discretionary basis but may be offered on a non- discretionary basis. Middleton tailors its advisory services to the individual needs of each client. We offer a framework

of five investment strategies that we use to build portfolios within the context of a client’s existing holdings, current objectives, and risk tolerance. For each client, a specific strategy or a combination of strategies may be appropriate. Please see Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss - for further information regarding our investment strategies. Our investment recommendations generally are limited to providing advice regarding:
• exchange-listed securities
• securities traded over-the-counter
• exchange traded funds (including open and closed end funds) • municipal securities
• mutual fund shares MIDDLETON & COMPANY, INC. - 5
• U.S. government securities
• corporate debt securities (other than commercial paper)
• commercial paper
• certificates of deposit
• foreign issuers
• warrants As a matter of policy, we avoid alcohol, tobacco and gaming stocks. All investments involve varying degrees of risk and investments will only be recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity, and suitability. Additionally, clients may impose restrictions on investing in certain securities or types of securities. In connection with the provision of advisory services, a Portfolio Manager works with each client to:
• create a Statement of Investment Policy to ensure the portfolio is invested in accordance with your specific goals and objectives;
• determine the appropriate asset allocation for your portfolio, based upon a number of factors, including income needs, investment horizon and risk tolerance;
• work with your professional team – attorney, accountant and/or financial planner – to ensure that the investment management of your portfolio is coordinated with your estate plan and tax situation; and
• assist our non-profit clients with return expectations and withdrawal assumptions to support long-term planning for operating budgets and capital projects.