Firm Description Atlas Capital Management Corp. (Atlas Capital) was founded in 1993 by Jerry L. Jacobs. The firm is federally registered with the SEC (Securities Exchange Commission) as a Registered Investment Adviser. Atlas Capital provides investment management to individuals, families and their related entities, trust and estates, and family businesses. Atlas Capital allocates the investment management assets of its client accounts, on a discretionary basis, among one or more of its proprietary asset management programs. In addition to our discretionary management services, we also provide non-discretionary consulting services to selected clients. Atlas Capital's proprietary programs have been designed to comply with the requirements of Rule 3a-4 of the Investment Company Act of 1940. Rule 3a-4 provides similarly managed investment programs with a nonexclusive safe harbor from the definition of an investment company. In accordance with Rule 3a-4, the following disclosure is specifically applicable to Registrant’s management of client assets. ERISA/IRC Fiduciary Acknowledgement When Adviser provides investment advice to Client regarding Client’s retirement plan account or individual retirement account, Adviser is a fiduciary 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 Adviser makes money creates some conflicts with your interests, so Advisers operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. At the opening of the account an employee of Atlas Capital or a designated representative i.e., the solicitor (see disclosures contained below within Item 4 and contained in Item 14), will obtain from the client information sufficient to determine the client’s financial situation and investment objectives. The account will receive individual treatment, meaning the client’s account is managed on the basis of the client’s financial situation and investment objectives. Atlas Capital will not commingle client assets (No Pooling) meaning the clients beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the client’s account. Each client retains indicia of ownership of the account (i.e., right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). At least quarterly Atlas Capital shall notify the client to advise Atlas Capital whether the client’s financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of his/her/its account. Atlas Capital shall be reasonably available to consult with the client relative to the status of the client’s account. All Assets are held at qualified custodians, who provide quarterly account statements directly to clients at their address of record or electronically if client so elects. Client acknowledges and understands that Atlas Capitals' management programs may involve above-average portfolio turnover which could negatively impact upon the net after-tax gain experienced by the client in non-qualified accounts. Client acknowledges that not all trades are expected to be profitable and there may be short-term losses, there will be instances where it will be necessary to reenter the market at a higher level than that of the last exit. Additionally, it is possible for clients to receive distributions from funds that create a taxable gain and corresponding tax liability when their account shown no actual gain or possibly a loss. Atlas Capital provides asset management services to owners of variable annuities. Atlas Capital provides management services by assisting with or making allocations through the annuity contract to fund sub- accounts of the insurance company’s variable account that in turn directly invest in a particular underlying fund. Atlas Capital does not recommend the purchase of variable annuities, nor does it Atlas Capital Management Corp. Page 5 ADV Part 2A – 12.31.2023 render any ongoing investment advice regarding the decision to continue to hold a variable annuity, whether to exchange a variable annuity, or whether to roll over the variable annuity. There may be more suitable variable annuities available to clients, and clients and prospective clients should speak with the representative that sold them the variable annuity or another financial professional to address any questions that they might have regarding these decisions. Atlas Capital does not receive or share in any of the commissions or other fees received by the agent, underwriter, or variable annuity sponsor. No client is required to purchase a variable annuity to receive Atlas Capital’s services. Principal Owner Jerry L. Jacobs is 100% stockholder of Atlas Capital Management Corp. There are no intermediate subsidiaries. Types of Advisory Services The primary type of advisory service offered by Atlas Capital is investment supervisory services (i.e., "asset management"). In addition to our discretionary management services, we also provide non- discretionary consulting services to selected clients. In performing its services, Atlas Capital is not required to verify any information received from the client or from the client's other professionals. Each client is advised that it remains his/her responsibility to promptly notify Atlas Capital when there is any change in his/her financial situation and /or financial objectives for the purpose of reviewing, evaluating, or revising services. At least quarterly the Adviser shall contact the client electronically, through the U.S. Mail or through the use of a custodial statement to determine whether the clients’ financial situation or investment objectives have changed. Managed Assets As of December 31st, 2023, Atlas Capital managed/consulted on $460,863,224. $443,133,315 for approximately 2540 accounts on a discretionary basis. In addition, Atlas Capital has consulted on approximately 180 additional accounts on a non-discretionary basis; these assets totaled approximately $17,729,909 dollars. Custody Fees Under Atlas Capitals’ Investment Management Agreement, assets held at Axos Advisor Services will be charged an annual custody fee based on the value of the clients account and/or may incur transaction fees when purchases or sales are made. Axos Advisor Services computes custody fees based on the Average Daily Balance of the account per the schedule below: Account value between $0 -$250,000 ............. 10 basis points (.10 of 1%) Account value between $250,001- $999,999 .... 6 basis points (.06 of 1%) Account value $1,000,000 and greater ............... 3 basis points (.03 of 1%) Transaction Cost(s) (Redemption fees for Mutual Funds) Mutual funds are purchased for Clients accounts that have no initial expenses. Adviser may purchase funds that impose short term redemption fees, however, when such funds are purchased, it is the practice of the Adviser to hold these funds until the short-term fees are waived. Client is advised that if Client terminates this management agreement and requests liquidation of assets, any redemption fees will be the sole responsibility of the Client. If Client requests partial withdrawal the same applies. Clients utilizing Atlas Capital’s Investment Consulting Agreement may incur transaction charges for each stock, mutual fund, fixed income security, or exchange traded fund (ETF) transaction. Adviser does not share in any redemption fees or transaction fees that are imposed by any fund or custodian. These charges are different than charges incurred by Investment Management Atlas Capital Management Corp. Page 6 ADV Part 2A – 12.31.2023 clients. When ETF’s are transacted for Client’s investment management accounts there may be a transaction fee imposed. This transaction cost is charged by the custodian or Broker/Dealer that has custody of the account. It is anticipated that by combining orders for multiple accounts the cost for each Client will be substantially less than if they were done individually. Although the purchases and sales are combined to minimize expenses, all Clients’ maintain an individual segregated account at the custodian. Client is advised that if Client terminates this management agreement and requests liquidation

of the assets the transaction costs may be greater than when bulk purchases were made. If client requests partial withdrawal the same applies. Adviser does not share in any transaction expenses charged by the custodian or Broker/Dealer. Regardless of the type of agreement all Clients are advised to check each fund’s prospectus for any redemption fees. Miscellaneous Non-Investment Consulting/Implementation Services. Neither Atlas Capital, nor any of our representatives, serves as an attorney and no portion of Atlas’ services should be construed as legal advice. To the extent requested by a client, Atlas may recommend the services of professionals for certain non-investment implementation purposes (i.e., attorneys, tax advisors, accountants, insurance agents, etc.), including any investment adviser representatives (IAR) of Atlas Capital. Atlas IAR’s may be tax preparers and licensed insurance agents and may perform certain tax preparation services and/or commissionable insurance sales in their individual capacity, separate and apart from the investment management services provided by Atlas Capital. The client is 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 from Atlas. Please Note: The recommendation by any Atlas IAR that a client utilize his/her tax preparation services and/or purchase an insurance commission product from him/her presents a conflict of interests, as the independent IAR has an economic incentive to recommend his/her tax preparation or insurance sales services based on the compensation to be received, rather than basing such recommendation on a particular client’s best interest. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify Atlas if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Atlas’ previous recommendations and/or services. Cash Positions As noted in our Strategy Descriptions in our Investment Management Agreement, certain strategies are designed to respond to certain market conditions and will hold exclusively cash or cash equivalents, such as money market funds. Two of our strategies – Perpetual Equity Growth and Perpetual World Equity Growth – do not “go to cash” based on market conditions and will typically remain fully invested. Regardless, even when fully invested, all our strategies maintain a cash position, which varies in size and changes from time to time. In calculating our fees, we include the value of any cash or cash equivalents in your account. There may be times when your fees will exceed the investment return in your account. The Registrant’s Chief Compliance Officer, Jerry Jacobs, or his designee, remains available to address any questions that a client or prospective client may have regarding this practice. Introduction from Primary Investment Professional/Solicitors Atlas Capital Management provides investment management services to clients who are introduced to the firm through the client’s primary investment professional, including an adviser that serves as a solicitor to Atlas Capital Management. In these type engagements, the client shall be requested to acknowledge and agree that: (1) at all times, the Investment Professional shall serve as the client’s primary investment professional, and shall be responsible for: (a) assisting client in determining the Atlas Capital Management Corp. Page 7 ADV Part 2A – 12.31.2023 client’s initial and ongoing suitability for Atlas’s investment portfolios and/or strategies, and (b) receiving/ascertaining client’s directions, notices, and instructions, and forwarding them to Atlas in writing. Atlas’s only obligation shall be to manage the assets consistent with the designated investment strategy. Atlas Capital Management shall be entitled to rely upon any such direction, notice, or instruction until it has been duly advised in writing of changes therein. (1) Atlas shall have no responsibility to the client for the failure of the Investment Professional to timely receive/ascertain/ forward/communicate any and all such directions, notices, and instructions; (2) Atlas is permitted to share account-related information with Investment Professional until such time as client notifies Atlas, in writing, to the contrary; and (3) if Atlas is directed to effect account transactions though a specific broker-dealer/custodian, Atlas will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative brokerage/custody arrangement. Higher transaction costs adversely impact account performance. Please see additional disclosure in Item 14 below. Please Note: Atlas Capital Management may occasionally reimburse certain broker dealers or investment advisers for certain expenses and the broker dealer or investment adviser may pass along those payments to the representative making a referral. These additional payments will not cause the client to pay additional money in management fees. Such additional expense reimbursements will come directly from Atlas Capital Management’s receipt of management fees and will be paid directly to the respective broker dealer or Registered Investment Advisory firm and not to any individual representative. This may present a conflict of interest in that the broker dealer, investment adviser or their representatives may make a referral based on the expectation of future expense reimbursements and not necessarily based on the quality of investment advice rendered. Atlas Capital Management attempts to resolve this expense reimbursement conflict by requiring preclearance from the Chief Compliance Officer prior to disbursing any funds. The CCO will determine whether any such reimbursement is material in amount or frequency to cause any additional concerns. The CCO may use his judgment in approving or denying such reimbursement. The solicitor will continue to receive a referral fee for the duration of the client’s relationship with Atlas Capital Management and therefore may have an incentive to continue the recommendation of Atlas Capital Management and its services. The Registrant’s Chief Compliance Officer, Jerry Jacobs, or his designee, remains available to address any questions that a client or prospective client may have regarding this arrangement. Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Atlas Capital Management) will be profitable or equal any specific performance level(s). Client Obligations In performing its services, Atlas Capital Management shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Atlas Capital Management if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Atlas Capital Management’s previous recommendations and/or services. At least quarterly the Adviser shall contact the client electronically, through the U.S. Mail or through the use of a custodial statement to determine whether the clients’ financial situation or investment Atlas Capital Management Corp. Page 8 ADV Part 2A – 12.31.2023 objectives have changed. Neither Atlas nor the client may assign the Investment Management Agreement without the prior written consent of the other party. Transactions that do not result in a change of actual control or management shall not be considered an assignment. A copy of Atlas’ written disclosure statement as set forth on Part 2A of Form ADV shall be provided to each client prior to or contemporaneously with the execution of the Investment Management Agreement.