Buckingham Capital Management, Inc. (“Buckingham Capital Management” or “BCM”) is an SEC-registered investment adviser with its principal place of business located in Ohio. Buckingham Capital Management, Inc. began conducting business in 1999. Buckingham Capital Management advertises under the name Buckingham Advisors. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).  Buckingham & Company, Owner  Jay Allen Buckingham, CFP®, CEO and Chief Compliance Officer, Buckingham & Company Shareholder We offer the following advisory services to our clients: A. PORTFOLIO MANAGEMENT We begin our portfolio management service by reviewing your present financial situation and gathering information relating to your goals, objectives, time horizons, and risk tolerance. We will review with you your present investment situation and the impact of your present investment plan. As part of this, we may, at our discretion, include a complimentary meeting to review your ongoing needs and objectives. If you elect to have us provide Investment Supervisory or Management Services, you will sign our Investment Advisory Agreement. Once you have signed the agreement, we will gather data from documents and interviews with you. We will work with you and your other advisers (your accountant, banker, or attorney, for example) to obtain information that, depending on your needs, may include:  Past financial history  Present financial condition  Family background  Short-term goals (such as college funding)  Long-term goals (such as retirement planning) Based on this information, we will create and manage a portfolio through which we will attempt to meet your investment goals. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:  Exchange-traded stocks  Over-the-counter-stocks  Foreign securities issuers  Corporate debt securities (other than commercial paper)  Certificates of deposit  Municipal Securities  US Government Securities  Bank Reserves  Exchange-traded funds (“ETFs”)  No-load mutual funds ETFs and mutual funds may invest in a wide variety of investments and may use investment strategies not used directly by our firm. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. We believe that reviews are key to the performance of your portfolio. We will review your portfolio to determine if your investment selections continue to be consistent with your stated goals. When reviewing your portfolio, we consider investment results, assess your ongoing and additional needs, determine if adjustments in the investment strategies are needed, and address any other concerns you bring to our attention. B. INVESTMENT CONSULTING SERVICES We also provide investment advice on a more focused basis. This may include advice on only specific investment and financial concerns of the client. We will discuss and gather information pertaining to your current financial situation in an effort to determine your goals, objectives, time horizon and risk tolerance. We may require you to complete a Risk Tolerance Profile Questionnaire to aid in the development of your investment policy. It is important we have a mutual understanding of your risk tolerance and investment objectives. Based upon the information you provide; we will prepare recommendations for your implementation. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. The Client will have the final decision-making authority regarding the implementation of any recommendations. C. RETIREMENT PLAN CONSULTING SERVICES We provide ongoing retirement plan consulting services to employers (“Client”) that sponsor qualified retirement plans including, but not limited to profit sharing, cash balance and 401(k) plans (“Plan”). As the needs of the plan sponsor dictate, Clients may choose to use any or all of these services: Fiduciary Services:  We will work with the client to determine an appropriate investment strategy that reflects the Plan Sponsor’s stated investment objectives for the management of the plan. Our firm will then review and evaluate the Client’s Investment Policy Statement (“IPS”), if any, to determine that the investment strategy of the Plan is consistent with the IPS. If the Client has no IPS or if the IPS needs to be modified, our firm will help prepare or modify a written IPS detailing the needs and goals, including

an encompassing policy under which these goals are to be achieved and monitored. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.  Based on our research and analysis, provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client shall have the final decision-making authority regarding the initial selection, retention and addition of investment options.  Assist the Client with the selection of a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder.  Perform analysis of the fees and expenses associated with the investments and the service providers to assist Client with its due diligence required under the Employer Requirement Income Security Act (“ERISA”). The goal of this investment due diligence process is to establish a comprehensive, systematic, and repeatable process that can be consistently employed by the Client in the selection and ongoing monitoring of the investment funds and service providers both as to their performance and the costs associated with the funds and services.  Perform provider searches and analysis of services provided by; bundled providers, recordkeepers, administrators and other service providers and assists Client with the selection of service providers on a periodic basis including assistance with requests for proposals, and the negotiation of the service agreement including the fees for the negotiated services to be rendered.  We may create, monitor, adjust, and rebalance asset allocation models (“Models”) for the Client’s use as an investment option provided to participants for use in assisting Plan participants in making asset allocation decisions for their investment portfolios. The Models would be designed to meet different investment objectives based on the participant’s risk level, investment horizon, and the participant’s investment options. Notwithstanding these services, the Plan participants and beneficiaries alone bear the risk of investment results from the options and asset allocations that they might select.  Perform benchmarking services, and provide analysis concerning the operations of the Plan.  Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options.  Meet with the Client on a periodic basis to discuss the reports and the investment recommendations.  Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. The Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). With respect to the foregoing Fiduciary Services, Buckingham Capital Management acknowledges that it is a fiduciary with respect to a Plan under Section 3(21)(A)(ii) of ERISA and, as such, is a co-fiduciary with the Trustee(s) of the Client’s Plan solely with respect to (a) the provision of Plan level investment advice to the Client; (b) the periodic reporting on, and analysis of, the investment options available under the Plan; and (c) the provision of advice to the Trustee(s) of the Plan regarding the elimination or addition of investment options available under the Plan. Notwithstanding the foregoing, the Client and the Trustee(s) shall have the final and conclusive responsibility for the investment options selected to be available under the Plan. Buckingham Capital Management will not be responsible for investment decisions made by the Plan participants with respect to the investment of their accounts. Buckingham Capital Management will not serve in the capacity as an “investment manager” as defined in Section 3(38) of ERISA and it does not have the power to manage, acquire, or dispose of any plan assets. Rather, Buckingham Capital Management shall provide non-discretionary investment advice. Non-Fiduciary Services:  Provide investment education to the Plan participants including: o Information about the terms of the plan and the benefits of participating in the plan o General information about financial and investment concepts o General information about the asset allocation models offered by the plan, without recommending any specific model to the participant o Tools that a participant can use to determine risk tolerance  Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. AMOUNT OF MANAGED ASSETS As of 02/29/2024, we were actively managing $850,270,367 of clients' assets on a discretionary basis plus $60,722,380 of clients' assets on a non-discretionary basis.