Vigilant Capital Management, LLC, dba Vigilant Wealth Management (“Vigilant”), is a private wealth management firm specializing in progressive investment and wealth planning solutions that are tailored to the unique needs of each client. Vigilant’s purpose is to help guide its clients in managing their wealth in such a way that it positively impacts their lives and the lives of future generations. Vigilant works with high‐net‐worth individuals and families, as well as select non‐profit, institutional, and corporate entities. Vigilant was founded in 2002. It is organized as a limited liability company under the laws of the State of Maine and is registered with the United States Securities and Exchange Commission (the “SEC” or “Commission”) as an investment advisor. Registration with the SEC does not imply a certain level of skill or training. The principal owner of Vigilant is Vigilant Capital, LLC, a limited liability company organized under Maine law. Vigilant provides discretionary investment management and wealth planning services to high‐net‐worth individuals and families, trusts, charitable organizations, foundations, endowments, and estates. Its discretionary investment management services may also be offered to corporations or business entities and to pension and profit‐sharing plans. Wealth Planning services are provided at the discretion of Vigilant and may not be appropriate for every client. Services may include, but are not limited to, providing advice and guidance in planning areas such as investment, financial, retirement, estate, tax, insurance, banking, credit, and charitable planning. Vigilant does not serve as an attorney or accountant, and no portion of our services should be construed as legal or accounting services. Accordingly, Vigilant does not prepare estate planning documents or tax returns. However, Vigilant may provide these advisory services to its clients or by working with an advisor who is an expert in a particular discipline (i.e., a lawyer, CPA or insurance specialist) or a combination thereof. Clients may elect to have Vigilant work with their existing advisors or select new advisors that may or may not be recommended by Vigilant. Vigilant does not and will not design, draft or implement legal, tax or insurance plans. Each client must seek proper legal, tax and insurance advice from a qualified professional advisor in these areas prior to implementation of any plan. Vigilant receives no compensation from any external provider of professional services or from the sale of any non‐investment product(s), such as insurance. Vigilant may, on a client’s behalf, participate in the negotiation of fees with a professional advisor. Clients are reminded that they are under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all March 30, 2023 implementation decisions and is free to accept or reject any recommendation made by Vigilant or its representatives. If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e. attorney, accountant, insurance agent, etc.), and not Vigilant, shall be responsible for the quality and competency of the services provided. Investment Management Services are provided by Vigilant in an agency capacity pursuant to an advisory agreement between the client and Vigilant by which each client grants to Vigilant full discretion to manage their investment assets. Vigilant employs a disciplined investment process that begins with an assessment of each client’s needs and goals, return expectations, risk tolerance, and investment constraints based upon information provided by each client. During this process and afterward by providing written notice to Vigilant, the client may impose restrictions on investing in certain securities or certain types of securities (as an example, certain clients may impose investment restrictions on Vigilant so that the client will be in compliance with investment restrictions imposed on the client by the client’s employer). Upon the completion of the assessment process, an Investment Policy Statement (hereinafter IPS) will be generated. This IPS will be utilized by Vigilant to determine the appropriate target asset allocation and the discretionary management of the client’s assets on an ongoing basis. The IPS will be reviewed and approved by the client at the inception of the relationship and will be reviewed and discussed periodically over time. Clients must notify Vigilant should there be any changes to their financial circumstances, needs, objectives and/or tolerance for risk or other circumstances relevant to management of their account(s). As an extension of Vigilant’s investment management and wealth planning services, Vigilant may offer Family Office Wealth Management services to certain qualified client families who desire not only our discretionary investment management services but

also our assistance with their complex needs regarding various wealth planning initiatives. Each family office relationship shall be unique and tailored to fit the specific needs and goals of that particular client. The services available to each family office client as well as the means of calculating the client’s fee shall be clearly stated in the client’s agreement. As discussed above, when providing wealth planning services under a Family Office Wealth Management engagement, Vigilant may work with a third‐party advisor who is an expert in a particular discipline (i.e., a lawyer, CPA or insurance specialist). Clients may elect to have Vigilant work with their existing third‐party advisors or select new advisors that may or may not be recommended by Vigilant. Vigilant is not responsible for the outcome of the advice or work provided by third‐party advisors. March 30, 2023 Investment accounts may consist of cash, money market funds, fixed income securities, equity securities, alternative investments, and exposure to other publicly traded asset classes that Vigilant and each client agree are in‐line with the IPS. Vigilant may utilize individual securities, sector securities, market‐index securities and publicly traded investment companies (i.e., mutual funds, Exchange Traded Funds (ETFs), etc.). Options contracts may be utilized for the purpose of establishing defensive positions and/or protecting profits and may be used to gain specific market exposures that complement Vigilant’s overall investment strategy at a given time. When consistent with a client’s investment objectives, Vigilant may allocate investment assets to “interval funds.” Investment companies structured as “interval funds” are generally designed for long‐term investors that do not require daily liquidity. Shares in interval funds typically do not trade on the secondary market. Instead, their shares are subject to periodic redemption offers by the fund at a price based on net asset value. Accordingly, interval funds are subject to liquidity constraints. Interval funds investing in securities of companies with smaller market capitalizations, derivatives, or securities with substantial market and/or credit risk tend to have the greatest exposure to liquidity risk. Generally, the interval funds recommended by Vigilant offer a two to three week period, on a quarterly basis, during which the client may seek the redemption of previously purchased interval funds. Vigilant follows a disciplined security selection process to build, manage and monitor client investment portfolios. This process is overseen by the Vigilant Investment Policy Committee (hereinafter IPC), which meets regularly to assess market conditions and to discuss existing portfolio positions or any recommended changes thereto. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could result in adverse tax consequences). If Vigilant recommends that a client roll over their retirement plan assets into an account to be managed by Vigilant, such a recommendation creates a conflict of interest if Vigilant will earn an advisory fee on the rolled over assets. If Vigilant provides a recommendation as to whether a client should engage in a rollover or not, Vigilant is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Vigilant. March 30, 2023 Vigilant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Vigilant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Vigilant determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Vigilant will be profitable or equal any specific performance level(s). Vigilant does not participate in wrap fee programs Vigilant primarily manages client accounts on a discretionary basis. This means that Vigilant is authorized to direct execution of transactions in its client accounts without transaction‐by‐ transaction consultation with the client. As of December 31, 2021, Vigilant managed approximately $2,200,862,557 of client assets on a discretionary basis and $0 of client assets on a non‐discretionary basis.