Firm Description PGA is a registered investment adviser with the SEC. Registration does not imply a certain level of skill or training. Currently, PGA manages, on a discretionary basis, equity, fixed income and balanced investment portfolios (e.g., portfolios allocated amongst both equity and fixed income securities) principally for high net worth and other individuals, including their trusts, self-directed retirement plans, IRAs, and charitable giving accounts (each a “Donor”) with Fidelity Charitable (“Discretionary Management Services”). Upon the specific request of a client, PGA provides advice regarding the retention of one or more other investment advisers registered under the Advisers Act of 1940, as amended (each a “Third- Party Adviser”), to manage certain client’s assets (“Consulting Services”). Consulting Services are provided on a non-discretionary basis. PGA and its predecessor companies have been in business since 1994. Principal Owners The principal owners of PGA are John Barker Sullivan and Richard S.F. Strabley. Types of Advisory Services PGA’s investment advisory services include Discretionary Management Services and Consulting Services (collectively, “Portfolio Management Services”). In addition, PGA intermittently publishes written pieces that explore targeted market topics (“Other Services”). John B. Sullivan, Richard S.F. Strabley, Derek C. Jaskulski, Thomas C. Wells. Matthew M. Hanson, Courtney H. Walsh, Heidi N. Peterson, David E. Smith and Leslie K. Klenk are authorized to provide the advisory services described in this Brochure on behalf of PGA. Discretionary Management Services. PGA works with each client to develop an individualized and cost effective asset allocation target which is based on numerous factors including the client’s investment goals/outcomes, investment time horizon, income requirements, expected future expenses (e.g., liquidity needs), tolerance for investment risk, tax and estate planning needs and philanthropic objectives (“Investment Goals”). This target is flexible and may be adjusted as a client’s Investment Goals change. These services are provided on a fully discretionary basis. PGA utilizes the asset allocation target to create an investment portfolio comprised of a mix of cash, equity securities and/or fixed income securities that complement a client’s Investment Goals. In the future, PGA may invest a client’s assets in other investment vehicles if consistent with PGA’s then-current economic and market outlook and the client’s Investment Goals. While clients may impose restrictions on investing in certain securities or types of securities, these limitations must be acknowledged by both PGA and the client. Upon request, and to complement these Discretionary Management Services, PGA works with clients and their representatives (e.g., attorneys and tax professionals), on a non-discretionary basis, to formulate and implement their philanthropic mission and related strategies. Upon appointment by a Donor, PGA also conveys Donor’s grant recommendations to Fidelity Charitable for consideration and approval. Consulting Services. Upon request of a client to perform Consulting Services, PGA shall: (1) advise on the retention of Third-Party Advisers; (2) monitor and evaluate the performance of client assets managed by Third-Party Advisers (in addition to any client assets subject to PGA’s Discretionary Management Services); (3) make recommendations to the client on the allocation of client assets among PGA and/or each Third-Party Adviser; and (4) implement procedures reasonably designed to help ensure that each Third-Party Adviser provides investment advisory services to the client consistent with the client’s Investment Goals and any investment restrictions acknowledged by both the Third-Party Adviser and the client. The client is responsible for retaining and terminating Third-Party Advisers and for issuing instructions relating to the allocation and reallocation of client assets among PGA and/or each Third-Party Adviser for investment. Other Services. PGA intermittently publishes written pieces that explore targeted market topics. These materials are made available, free of charge, to clients and a limited number of other persons who request copies. NOTE: This Brochure (Part 2A of Form ADV) describes the Discretionary Management Services, Consulting Services and Other

Services provided by PGA to its clients. If a client retains a Third- Party Adviser to manage a portion of the client’s assets (“Third-Party Advisory Services”), the client should review the Third-Party Adviser’s Firm Brochure (Part 2A of Form ADV) for a description of its business and investment advisory services as well as related information including, but not limited to, fees and compensation, types of clients serviced, investment processes/strategies and risks of loss, disciplinary information, financial industry activities and affiliations, transaction and brokerage practices, custody arrangements for client accounts and oversight of client account activity. Investment Advisory Agreement Generally. As an investment adviser, PGA owes a fiduciary duty to each client and must act in the best interests of each client when rendering Portfolio Management Services. PGA requires that each client enter into an Investment Advisory Agreement (“Agreement”) prior to PGA’s performance of any Portfolio Management Services for the client. An Agreement is a written contract between PGA and the client and sets forth the terms of the Portfolio Management Services to be rendered to the client. Under the Agreement between PGA and Fidelity Charitable, Fidelity Charitable appoints PGA, per the nomination of the Donor, to provide Discretionary Management Services to the Donor’s charitable gift fund (a “Donor Advised Fund”) consistent with the Donor’s investment criteria and Fidelity Charitable’s investment guidelines. Under the Agreement, PGA acknowledges that Fidelity Charitable is the legal owner of the assets of a Donor Advised Fund and that Fidelity Charitable is PGA’s client for purposes of any Discretionary Management Services rendered to the Donor Advised Fund. The Agreement also requires PGA to invest the assets of a Donor Advised Fund solely for the benefit of Fidelity Charitable’s philanthropic mission. Typically, an Agreement between PGA and a client may be terminated upon 30 days’ prior written notice to the other party. The Agreement between Fidelity Charitable and PGA is terminable upon written notice to the other party. Under the terms of an Agreement between PGA and a client, the Agreement shall not be assigned without the client’s or the client’s authorized representative’s consent. PGA does not maintain physical custody of securities or any other assets of its clients (“Assets”). Each Agreement requires that physical custody of client Assets subject to Portfolio Management Services be maintained by a “qualified custodian” (each a “Custodian”). “Qualified custodians” include broker-dealers. Typically, the client identifies the Custodian in the Agreement executed with PGA. Each Agreement also provides that the client has the right to designate broker-dealers through which securities transactions will be executed on behalf of the client’s investment portfolio. In the absence of specific instructions from the client, PGA selects one or more broker- dealers to affect securities transactions. For more information regarding PGA’s brokerage practices, see “Brokerage Practices”. Discretionary Management Services. Under an Agreement, the client appoints PGA as its agent and attorney-in-fact, with full authority and discretion, on the client’s behalf and risk, to purchase and sell securities in such amounts, at such prices and in such manner as PGA may deem advisable for the client’s investment portfolio. Each Agreement, however, requires the client to retain all proxy-voting responsibilities with respect to the client’s Assets managed by PGA. Consulting Services. An Agreement provides that Consulting Services are rendered on a non- discretionary basis and that the client, not PGA, is responsible for retaining and terminating Third- Party Advisers and for issuing instructions relating to the allocation and reallocation of client Assets among PGA and/or each Third-Party Adviser for investment. Each Agreement requires that management services provided by a Third-Party Adviser be rendered pursuant to terms and conditions set forth in a separate investment advisory agreement between the client and the Third- Party Adviser. Assets Under Management As of December 31, 2023, PGA managed $894,628,115 in client Assets on a discretionary basis. As of the same date, PGA provided Consulting Services on a non-discretionary basis to client Assets valued at approximately $47,142,997.