Hall Capital Management Company, Inc. (“Hall Capital or the Firm”), a Massachusetts corporation, founded in 1997. Robert F. Hall is the Principal Owner, Chairman and Chief Compliance Officer of Hall Capital. Investment Management Services Hall Capital provides discretionary and non-discretionary investment management services, as agreed upon between Hall Capital and its clients, including the following advisory services:
• Buys, sells, converts, exchanges, trades in and deals with any security, through registered broker-dealers, for the account of its investment advisory clients, at such prices and in such manner as Hall Capital deems advisable.
• Instructs the advisory client’s custodian to deliver securities sold, exchanged or otherwise disposed of from the account of the investment advisory client against payment and to pay cash for securities delivered to the custodian or trustee upon acquisition for such account. Hall Capital has clients with investment goals that are often unique to them. At the outset of the client relationship, Hall Capital discusses the client’s particular objectives as well as determines the client’s tolerance for risk and time horizon. This dialogue results in an approach that Hall Capital believes effectively accomplishes those objectives and is suitable given the client’s individual profile. Asset allocation ranges are established during this discussion, as well as any restrictions a client may wish to impose on certain securities or types of securities. Financial Planning Services Hall Capital offers financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate planning, charitable giving, tax planning, and capital needs planning. Clients understand that when Hall Capital is engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. Hall Capital meets with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information; sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. The financial plan may include both long and short-term considerations, depending upon the individual scenario. Upon completion, a plan is presented to the client. At this meeting, the client is provided with recommendations that are deemed to be compatible with the client’s stated goals and objectives. An implementation schedule is reviewed with the client to determine which steps will be pursued, and with whom the steps may be accomplished. The client is under no obligation to utilize additional services of Hall Capital and its representatives and is under no obligation to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. Tax Preparation Services In certain circumstances, Hall Capital will prepare individual and corporate tax returns on behalf of clients. In addition, Hall Capital may provide clients with consulting services on tax-related matters. Consulting Services to Retirement Plan Sponsors Hall Capital provides investment advisory services to plan sponsors of certain qualified retirement plans which meet the Internal Revenue Code requirements and the Employee

Retirement Security Act of 1974 (ERISA), such as profit-sharing plans, 401(k) plans, 403(b) plans, and 457 plans. The Firm provides recommendations as to the appropriate, limited array of investment options to be chosen from the mutual funds available through the plan’s third-party administrator investment platform. At the client’s request, Hall Capital also provides informational and educational services to plan participants through seminars, employee meetings, and other manners of communication to assist the participants in learning how to properly utilize the plan and the investment options therein. Hall Capital does not have custody, control, discretionary authority, responsibility for execution and does not take responsibility for valuation, recordkeeping, or proxy voting. Tailored Relationships Hall Capital tailors’ investment advisory services to the individual needs of the client. Hall Capital clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to Hall Capital in writing. Clients will retain individual ownership of all securities. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs Hall Capital does not participate as a portfolio manager or sponsor of a Wrap Fee Program. Client Assets As of December 31, 2023, Hall Capital managed $342,685,575 in assets under management; We manage $340,920,661 on a discretionary basis and $1,764,914 on a non-discretionary basis.